VCS PCN at train station...no mention of by-laws

Hi, I received a rejection letter to my appeal, which also failed to address the 'station land' issue. I have pasted their lengthy reply.

We refer to your appeal in respect of the above Charge Notice (CN) received on 22/03/2018.
Having considered the points you have raised and reviewed our records, we are unable to accept your appeal. Our
main reason(s) for this decision are as follows:
We note that you have declined to name the driver of your vehicle at the time of the incident in question. It is
important that we make you aware that in this case we may pursue you as the registered keeper of the vehicle for
the outstanding Charge, as per Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) .
The notice sent to you clearly states: Please be warned: that if, after the period of 28 days beginning with the day
after the Issue Date of this Notice, the amount of the unpaid Parking Charge specified in this Notice has not been
paid in full and we do not know both the name of the driver and a current address for service for the driver, we will
have the right to recover from the registered keeper, any unpaid balance of the Parking Charge. This Notice will be
deemed to have been received by you on the second working day after the Issue Date stated above unless the
contrary is proved.
As members of the International Parking Community's (IPC) Accredited Operator Scheme, it is necessary for us to
evidence to the IPC that we have relevant authority to undertake parking management at the site concerned and that
our signs at that location are compliant in setting out the relevant terms and conditions of use. We will only answer
pertinent points at this stage.
The signs at the car park make it clear that the land is private property and that a Charge of £100 will be levied if
vehicles park outside of the Terms and Conditions displayed. Signs state that all vehicles must park wholly within the
markings of a designated parking bay. The above detailed vehicle was not correctly parked within the bay markings
therefore you became liable for the Charge advertised.
We maintain that the signs on this site meet the requirements set by the International Parking Community (IPC) Code
of Practice . The signs are large, prominent and legible ,so that any reasonable user of the car park would be aware
of their existence and nature, and would have a fair opportunity to read them if he or she wished to do so. It can
never be a defence to a claim in contract law to say, "I did not read the terms", so long as the existence of those
terms is reasonably advertised.
We note your comments in relation to the amount of the Charge Notice; our charges are neither extravagant nor
unconscionable and as such, are commercially justified and legitimately enforceable. This was supported by the
Supreme Court's decision in the case of ParkingEye v Beavis ([2015].
We are contracted by the landowner to manage and enforce parking on their private land on their behalf. This site
has been audited by the International Parking Community (IPC) and a copy of our authority has been provided to
them as part of that audit process. However, whilst we maintain that we do, in fact, have the authority of the
landowner to operate upon this site (being the principal in
the contract); the existence of this document has no legal bearing on the contract formed with the motorist. (See
Vehicle Control Services v HMRC [2013] EWCA Civ 186, para 22 per Lewison LJ).
Whilst you have made a request under the principle 6 of the Data Protection Act 1998, unfortunately this does not
mean that you can simply demand us to cease processing your information and you fail to explain or meet the
requirements for a " section 10 Notice" within your letter as detailed below.
We are registered with the ICO for the processing of data which relates to the enforcement and recovery of parking
charges and in respect to you this related to the matter of a Charge Notice (CN), Ref VCS1968700 which was
issued to a vehicle registration .......on the date in question.
In the first instance you may find it helpful to review the information on the Information Commissioners Office website. Your request in principle can only be dealt with if the processing of information "causes
unwarranted and substantial damage or distress" and you must outline this in your request which you have failed to
do
We have fully reviewed this case and we are satisfied that the Charge Notice was correctly issued. We are unable to
accept the mitigating circumstances raised in your representations, your appeal is therefore rejected and the Charge
will stand; photographic evidence which supports this can be viewed at .......


any further advice? Thanks for any help.
Is there any way of determining whether this is in fact station land - it is Northfield station park and ride - centro.