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       #Post#: 106257--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: InterCity125
       Date: January 17, 2026, 4:27 am
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > I'm not sure I would suggest to DVLA what their own response
       wording should be, but I think the wording about their failure
       to properly consider is great.
       >
       > If you've reached the end of the DVLA process, you can refer
       it to an Independent Complaints Assessor. They won't
       "relitigate" the issue, but will look at whether DVLA's handling
       was sufficient.
       >
       --- End Quote ---
       Point taken.
       I have altered the wording slightly.
       I personally feel that it is important to reflect to the DVLA
       the precise nature of their failing and that by setting out a
       potential response I feel that the goal is achieved.
       #Post#: 106259--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: Hashim
       Date: January 17, 2026, 4:34 am
       ---------------------------------------------------------
       Thank you for this, I will pursue with DVLA but how do I go
       about representing to Popla now which I believe is the next
       stage.
       Thank you once again.
       Hashim
       #Post#: 106641--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: Hashim
       Date: January 20, 2026, 6:15 am
       ---------------------------------------------------------
       Dear Gents
       Can someone help me with the next stage please which is Popla
       appeal..
       thanks
       Hashim
       #Post#: 106688--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: InterCity125
       Date: January 20, 2026, 10:06 am
       ---------------------------------------------------------
       POPLA Parking Appeal for PCN reference xxxxxxxx
       I am the registered keeper of vehicle registration xxxx xxx
       I wish to appeal the PCN on the grounds that there is no PoFA
       invoked keeper liability at this car park site.
       The driver is not known to the parking operator and there is no
       legal requirement for me to identify the driver in this
       circumstance.
       Furthermore, the PCN issued by Euro Car Parks is unlawful as it
       falsely claims that PoFA can be applied in order to move
       liability from the unknown driver to the known keeper - this
       appears to be a deliberately misleading claim designed to
       pressure the keeper into paying.
       The claim of keeper liability is also a clear breach of the
       operator's own Code of Conduct which EXPRESSLY PROHIBITS the
       mentioning of PoFA (in a PCN) in instances where PoFA cannot
       apply - any breach of the Code of Conduct is also a breach of
       the operators KADOE agreement - as a result, the keeper data
       released to the operator has also been misused.
       Furthermore, the issues with PoFA were outlined in my original
       keeper appeal but again Euro Car Parks issued a response which
       once again mis-stated their true legal position and again
       implied that liability could be moved onto the keeper - this
       appears to illustrate the incompetence of the Euro Car Park
       staff who are clearly mishandling valid appeals. It also
       illustrates the fact that Euro Car Parks are not accessing the
       nature of the land before commencing their parking enforcement -
       as a result they are issuing unlawful and non-compliant NtKs.
       The facts in the case are;
       The land at Fullwell Cross Leisure Centre is owned by the London
       Borough of Redbridge.
       The London Borough of Redbridge is a Council and therefore,
       legally, constitutes a traffic authority.
       The car park is therefore council owned and, in law, represents
       'a parking place provided by a traffic authority.'
       It appears that Euro Car Parks have been appointed by the
       council to help manage the car park.
       Whilst it appears that Euro Car Parks are entitled to help
       manage the car park, this DOES NOT automatically make it a
       location where PoFA can suddenly be used to invoke keeper
       liability.
       In particular, Schedule 4 of PoFA confirms that point as
       Paragraph 3(1)(b) expressly excludes 'a parking place which is
       provided or controlled by a traffic authority' from being
       'relevant land' for the purposes of PoFA.
       The car park at Fullwell Cross Leisure Centre is not therefore
       defined as 'relevant land' for the purposes of PoFA and
       therefore liability can never be moved from the driver to the
       keeper as Euro Car Parks are continually stating.
       I now invite POPLA to uphold this appeal.
       Best wishes,
       xxxxx xxxxxxxx
       #Post#: 106784--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: Hashim
       Date: January 21, 2026, 4:49 am
       ---------------------------------------------------------
       Thank you Intercity125 for drafting the appeal.
       Just looking at the appeal process, it's asking me to choose on
       what basis am I appealing:
       1. I was not improperly parked.
       2. Extreme circumstances prevented me from parking correctly.
       3. Other
       which one should I be picking.
       Thanks
       Hashim
       #Post#: 106788--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: InterCity125
       Date: January 21, 2026, 5:21 am
       ---------------------------------------------------------
       Other
       If it then asks for more details you should state "No keeper
       liability"
       #Post#: 106789--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: InterCity125
       Date: January 21, 2026, 5:25 am
       ---------------------------------------------------------
       --- Quote from: InterCity125 link ---
       >
       > POPLA Parking Appeal for PCN reference xxxxxxxx
       >
       >
       > I am the registered keeper of vehicle registration xxxx xxx
       >
       > I wish to appeal the PCN on the grounds that there is no PoFA
       invoked keeper liability at this car park site.
       >
       > The driver is not known to the parking operator and there is
       no legal requirement for me to identify the driver in this
       circumstance.
       >
       > Furthermore, the PCN issued by Euro Car Parks is unlawful as
       it falsely claims that PoFA can be applied in order to move
       liability from the unknown driver to the known keeper - this
       appears to be a deliberately misleading claim designed to
       pressure the keeper into paying.
       >
       > The claim of keeper liability is also a clear breach of the
       operator's own Code of Conduct which EXPRESSLY PROHIBITS the
       mentioning of PoFA (in a PCN) in instances where PoFA cannot
       apply - any breach of the Code of Conduct is also a breach of
       the operators KADOE agreement - as a result, the keeper data
       released to the operator has also been misused.
       >
       > Furthermore, the issues with PoFA were outlined in my original
       keeper appeal but again Euro Car Parks issued a response which
       once again mis-stated their true legal position and again
       implied that liability could be moved onto the keeper - this
       appears to illustrate the incompetence of the Euro Car Park
       staff who are clearly mishandling valid appeals. It also
       illustrates the fact that Euro Car Parks are not assessing the
       nature of the land before commencing their parking enforcement -
       as a result they are issuing unlawful and non-compliant NtKs.
       >
       >
       >
       >
       > The facts in the case are;
       >
       > The land at Fullwell Cross Leisure Centre is owned by the
       London Borough of Redbridge.
       >
       > The London Borough of Redbridge is a Council and therefore,
       legally, constitutes a traffic authority.
       >
       > The car park is therefore council owned and, in law,
       represents 'a parking place provided by a traffic authority.'
       >
       > It appears that Euro Car Parks have been appointed by the
       council to help manage the car park.
       >
       > Whilst it appears that Euro Car Parks are entitled to help
       manage the car park, this DOES NOT automatically make it a
       location where PoFA can suddenly be used to invoke keeper
       liability.
       >
       > In particular, Schedule 4 of PoFA confirms that point as
       Paragraph 3(1)(b) expressly excludes 'a parking place which is
       provided or controlled by a traffic authority' from being
       'relevant land' for the purposes of PoFA.
       >
       > The car park at Fullwell Cross Leisure Centre is not therefore
       defined as 'relevant land' for the purposes of PoFA and
       therefore liability can never be moved from the driver to the
       keeper as Euro Car Parks are continually stating.
       >
       >
       >
       > I now invite POPLA to uphold this appeal.
       >
       >
       >
       >
       > Best wishes,
       >
       >
       >
       > xxxxx xxxxxxxx
       >
       --- End Quote ---
       #Post#: 106791--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: InterCity125
       Date: January 21, 2026, 5:26 am
       ---------------------------------------------------------
       Updated the appeal as I noticed a spelling error.
       #Post#: 107692--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: Hashim
       Date: January 28, 2026, 7:58 am
       ---------------------------------------------------------
       Hello
       Received a further correspondence from DVLA.
  HTML https://ibb.co/wNNhMrM2
       Thanks
       Hashim
       #Post#: 107699--------------------------------------------------
       Re: Euro car park - Fullwell cross Leisure centre.
   DIR By: InterCity125
       Date: January 28, 2026, 8:29 am
       ---------------------------------------------------------
       --- Quote from: Hashim link ---
       >
       >
       > Hello
       >
       > Received a further correspondence from DVLA.
       >
       >
  HTML https://ibb.co/wNNhMrM2
       >
       >
       > Thanks
       >
       > Hashim
       >
       --- End Quote ---
       Okay.
       She addresses some points but still sidesteps the main complaint
       - the clear misuse of your data once they'd obtained it.
       I can draft a response - give me a couple of days.
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