Highview Parking scam query

bazster

Looks to me like it's got all the key points in it! Bigger isn't necessarily better and some of the templates are beginning to read like War and Peace!

Redx

whilst I take the point, it seems to me that the top PE thread in the post #3 link looks better and easily adapted https://forums.moneysavingexpert.com/discussion/comment/66321761#Comment_66321761 by changing it from PE to Highview , especially as Highview seem to be contesting them with evidence packs that then need rebuttal replies and will contain a lot more than the above popla appeal contains

they only get one chance at this, plus you dont know if you get a good assessor or not, seems to be some new ones at the moment, so why take the risk ?

either way, only the OP can decide based on our replies, but my reply is I would rather use the adapted PE one and not the one in the previous post

brutal_deluxe

Redx wrote: »

looks nothing like a proper popla appeal to me, see my reply in post #2 , have a look through those examples, or search the forum for a recently approved highview popla appeal

look for any supermarket overstay popla appeal, or similar overstay appeal like an anpr PE appeal (like aldi or lidl or morrissons etc)

We have tried to base it on the main points from the examples elsewhere here. Is it anything specifically which doesnt look right? I don't want to tell her it's fine when it's not!

Redx

compare it to the link I posted, that is your task not mine, you asked for comments and critique so that is what I provided, having seen and skim read many popla appeals written on here and frankly I think its nowhere near detailed enough despite what others think

in fact, I cannot see why you didnt just use one of the many examples coupon-mad linked to with here post #3 link, which I mentioned in my first reply

I just think you are reinventing the wheel when it didnt need any changes apart from maybe changing the PPC name in an existing and approved appeal

brutal_deluxe

Redx wrote: »

compare it to the link I posted, that is your task not mine, you asked for comments and critique so that is what I provided, having seen and skim read many popla appeals written on here and frankly I think its nowhere near detailed enough despite what others think

in fact, I cannot see why you didnt just use one of the many examples coupon-mad linked to with here post #3 link, which I mentioned in my first reply

I just think you are reinventing the wheel when it didnt need any changes apart from maybe changing the PPC name in an existing and approved appeal

Yeh I see your point. Was worried about waffling where in fact it seemed to me that it was probably the main points that the assessor was looking for.

Nonetheless, I'm gonna have another look through the examples and pad it out with some further reasoning related to this incident. Thanks again for the feedback!

BD

Redx

brutal_deluxe wrote: »

Yeh I see your point. Was worried about waffling where in fact it seemed to me that it was probably the main points that the assessor was looking for.

Nonetheless, I'm gonna have another look through the examples and pad it out with some further reasoning related to this incident. Thanks again for the feedback!

BD

good, read post #9 of this thread

https://forums.moneysavingexpert.com/discussion/5047838 where coupon-mad recently advised another member which template appeal to use (the one I mentioned)

and her advice here too https://forums.moneysavingexpert.com/discussion/5036013

or this difficult to read one https://forums.moneysavingexpert.com/discussion/5027349

a simple forum search using highview popla appeal in the search box yields loads of hits

post #7 of this actual thread of yours actually told you which ones to adapt, the post by coupon-mad herself

brutal_deluxe

Ok we've adapted suggested points (from coupon_mad etc) in relation to this appeal. Personally I've advised there's too much in there, what do you think? Does it make sense?

Dear Sirs,

I wish to appeal the parking charge on the following grounds:

1) The amount is neither a genuine tariff/fee for parking, nor is it based upon any genuine pre-estimate of loss to Highview Parking or the Landowner. I believe that the £70 charge is not a genuine pre-estimate of loss or is unreasonable in proportion to the alleged 31 minute overstay, and should not be enforced. A full unredacted breakdown is required of how the amount of the charge was calculated purely in relation to this instance. It has been made aware from Court rulings and previous POPLA adjudications that the cost of running the business may not be included in these pre-estimates of loss.

If Highview Parking present what they describe as a GPEOL statement, I require them to show full documentary evidence regarding exactly when this 'pre-estimate of loss' was discussed with the Landowner or at any substantive meeting within the Operator's Senior Management. How/when were these calculations made and on what basis? Bearing in mind how many of their cases actually go to POPLA, what steps were taken to account for the 98% which do not? I put Highview Parking to strict proof that they ever had such a meeting.

If there was no meeting to discuss the £70 charge in advance then there was never a pre-estimate of loss discussion at all., as was found in April 2013 in 1IR65128 Brookfield Aviation Int. Ltd. v Van Boekel, where by HHJ Hand QC concluded in his summary at 94:
''I do not believe the evidence...that there was ever an attempt at a genuine pre-estimate of loss. I have found that there was no meeting in 2007...it seems to me that a conclusion that there was never any attempt at a genuine pre-estimate of loss is of some significance...Finally, the fact that the figure was arrived at by reference to what pilots might be prepared to tolerate...shows to my mind that in so far as the Claimant made any calculation as to amount, that calculation related to the balance between deterring breach and enforcing the notice period on the one hand and deterring recruitment on the other. In short, the sum stipulated for was not a genuine pre-estimate of loss but an “in terrorem” sum to deter breach and as such is a penalty.''

2) Highview Parking is not the landowner and do not have the standing to offer contracts to drivers nor to bring a claim in their own right. I request a copy of the contract between Highview Parking and Tesco, containing relevant information which includes the necessary contractual written authority for the issue and enforcement of the Parking Charge Notice.

I put Highview Parking to strict proof to provide an unredacted, contemporaneous copy of the contract with the Landowner, which - to demonstrate standing and authority - must specifically state that Highview Parking can make contracts with drivers themselves and that they have full authority to pursue charges in court in their own name. A witness statement to the effect that a contract is in place will not be sufficient because it will not show which restrictions are to be enforced, what the times/dates/details of enforcement are. How will I know that the landowner contract allows Highview Parking to charge £70 for this particular contravention if the contract is not produced? Showing a piece of paper signed by someone who has never seen the actual contract, saying merely that Highview Parking can put up signs and 'issue parking charges' would not prove that this charge is within the contract nor will it show any standing of this site agent.

3) No creditor identity. The notice refers to Highview Parking LTD but It has not been disclosed exactly who is making the claim and in what capacity. I request to know who the actual creditor is making this £70 charge demand. It has not been disclosed exactly who is making the claim and in what capacity.

4) No contract. The signage was not sufficiently prominent nor clearly worded and consideration did not flow from both parties, so there was no contract formed. I have personally revisited the site in question. I believe the signs and any core parking terms that the parking company are relying upon were too high and too small for any driver to see, read or understand when driving into this car park. I request that the operator show evidence and signage map/photos on this point - specifically showing the height of the signs and where they are at the entrance, whether a driver still in a car can see and read them when deciding to drive in.

In any case, unless signs are seen and understood before parking, they are not imported into any contract. In a free car park, where the Operator does not own the land (the named principal being the only party capable of offering the spaces and other amenities in the facility), there is no possibility of a contract, since no consideration can flow between a driver and a site agent. No money/offer/promise/permit or any other tangible nor implied nor executory consideration was capable of being exchanged with Highview Parking in this case.

No reasonable person would have accepted such onerous parking terms and I contend the extortionate charge was not 'drawn to his attention in the most explicit way' (Lord Denning, Thornton v Shoe Lane Parking Ltd [1971] 2 QB 163, Court of Appeal). Lord Denning continued: 'The customer is bound by those terms as long as they are sufficiently brought to his notice beforehand, but not otherwise. In {ticket cases of former times} the issue...was regarded as an offer by the company. That theory was, of course, a fiction. No customer in a thousand ever read the conditions. In order to give sufficient notice, it would need to be printed in red ink with a red hand pointing to it - or something equally startling.'

5) The ANPR system is unreliable and neither synchronised nor accurate. The charge is founded entirely on two photos of my vehicle entering/leaving the car park at specific times. I put Highview Parking to strict proof that their ANPR system is not fundamentally flawed because of known issues such as missing checks and maintenance of the timer/cameras and the possibility of two visits being recorded as one. The Operator's proof must show checks relating to my case/my vehicle. (The 'two visits recorded as one' problem is very common and is even mentioned on the BPA website as a known issue). The BPA says: ''As with all new technology, there are issues associated with its use:
Repeat users of a car park inside a 24 hour period sometimes find that their first entry is paired with their last exit, resulting in an ‘overstay’. Operators are becoming aware of this and should now be checking all ANPR transactions to ensure that this does not occur.''

Since I am merely the registered keeper, I have no evidence to discount the above possibilities. Highview Parking show no parking photographs so they cannot say for certain that the car was not involved in non-parking related activity - e.g. queuing, nor can they show the car did not leave the site and return.

This could easily be a case of two visits, or if my vehicle was on site for the time shown, I suggest that it may well not have been 'parked' for more than 2 hours. Due to the site location, entry and exit is often into congested one-way traffic, this car park site frequently becomes gridlocked at peak times, resulting in long queuing periods on the site. Nonetheless, there is an increased likelihood that this was the case, and evidence is required to show that the car was not queuing for a substantial period of time. I require Highview Parking to rebut these assertions.

I agree with the BPA that this ANPR technology has issues associated with its use. These also include (but are not limited to) synchronisation errors, buffering, faults with the timer, faults with one or other of the cameras, faults with the wireless signals and differences between the settings of the in/out clocks. The operator appears to use WIFI with an inherent delay through buffering, so "live" is not really "live". Hence without a synchronised time stamp there is no evidence that the image is ever accurate to the minute.

In addition, the BPA CoP contains the following in paragraph 21:
''You may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as you do this in a reasonable, consistent and transparent manner. Your signs at the car park must tell drivers that you are using this technology and what you will use the data captured by ANPR cameras for.''

Highview Parking fail to operate the system in a 'reasonable, consistent and transparent manner'. They place signs far too high to see on arrival and these are not lit, so there is no opportunity for drivers in moving traffic at the entrance to be 'informed that this technology is in use and what the Operator will use the data captured by ANPR cameras for'. I contend that as well as being unreliable, this is a non-compliant ANPR system being merely a secret high-up spy camera - far from 'transparent' - unreasonably 'farming' the data from moving vehicles at the entrance & exit and neither 'managing, enforcing nor controlling parking' since the cameras are not concerned with any aspect of the actual parking spaces, nor any parking event at all.

This concludes my appeal.

Thanks! BD

brutal_deluxe

PS here is a shot of the entrance to the car park. I think the little rectangular sign above the in-set entrance relates to parking but who within reason is able to stop and examine that before deciding not to enter??!

brutal_deluxe

Redx wrote: »

good, read post #9 of this thread

https://forums.moneysavingexpert.com/discussion/5047838 where coupon-mad recently advised another member which template appeal to use (the one I mentioned)

and her advice here too https://forums.moneysavingexpert.com/discussion/5036013

or this difficult to read one https://forums.moneysavingexpert.com/discussion/5027349

a simple forum search using highview popla appeal in the search box yields loads of hits

post #7 of this actual thread of yours actually told you which ones to adapt, the post by coupon-mad herself

OK I've had a look at all the examples and adapted bits from all of them to the points we feel are valid in this case. Could you PLEASE just take a quick look before she sends it? I actually think signage is a big one in this case - the entry sign is ridiculous (see picture above) Also I could not find ANY breakdown of 'terms and conditions' anywhere else on the site.

Dear Sirs,

I wish to appeal the parking charge on the following grounds:

1) The amount is neither a genuine tariff/fee for parking, nor is it based upon any genuine pre-estimate of loss to Highview Parking or the Landowner. I believe that the charge is not a genuine pre-estimate of loss or is unreasonable in proportion to the alleged overstay, and should not be enforced. A full unredacted breakdown is required of how the amount of the charge was calculated purely in relation to this instance. It has been made aware from Court rulings and previous POPLA adjudications that the cost of running the business may not be included in these pre-estimates of loss, for example; signage, ANPR maintenance and/or general administration. Not only are those costs tax deductible, but were no breaches to occur in that car park, the cost of parking 'enforcement ' would still remain the same.

According to the Unfair Terms in Consumer Contract Regulations, parking charges for breach on private land must not exceed the cost to the landowner during the time the motorist is parked there. For the record, the alleged contravention was of a duration of thirty one minutes. The Office of Fair Trading has stated that: ''a ‘parking charge’ is not automatically recoverable simply because it is stated to be a parking charge, as it cannot be used to state a loss where none exists.''

This Operator cannot demonstrate any initial quantifiable loss. The parking charge must be an estimate of likely losses flowing from the alleged breach in order to be potentially enforceable. Where there is an initial loss directly caused by the presence of a vehicle in breach of the conditions (e.g. loss of revenue from failure to pay a tariff) this loss will be obvious. An initial loss is fundamental to a parking charge and, without it, costs incurred by issuing the parking charge notice cannot be said to have been caused by the driver's alleged breach. The Operator would have been in the same position had the parking charge notice not been issued, and would have had many of the same business overheads even if no vehicles breached any terms at all. There is no genuine loss being pursued.

Neither is this charge 'commercially justified'. In answer to that proposition from a PPC about the ParkingEye v Beavis small claims decision (now being taken to the Court of Appeal by Mr Beavis anyway) POPLA Assessor Chris Adamson has stated in June 2014 that:

''In each case that I have seen from the higher courts,...it is made clear that a charge cannot be commercially justified where the dominant purpose of the charge is to deter the other party from breach. This is most clearly stated in Lordsvale Finance Plc v Bank of Zambia [1996] QB 752, quoted approvingly at paragraph 15 in Cine Bes Filmcilik Ve Yapimcilik & Anor v United International Pictures & Ors [2003] EWHC Civ 1669 when Coleman J states a clause should not be struck down as a penalty, “if the increase could in the circumstances be explained as commercially justifiable, provided always that its dominant purpose was not to deter the other party from breach”.

This supports the principle that the aim of damages is to be compensatory, beginning with the idea that the aim is to put the parties in the position they would have been in, had the contract been performed. It also seems that courts have been unwilling to allow clauses designed to deter breach as this undermines the binding nature of the initial promise made. Whilst the courts have reasonably moved away from a strict interpretation of what constitutes a genuine pre-estimate of loss, recognising that in complex commercial situations an accurate pre-estimate will not always be possible, nevertheless it remains that a charge for damages must be compensatory in nature rather than punitive.''

2) Highview Parking is not the landowner and do not have the standing to offer contracts to drivers nor to bring a claim in their own right. Highview Parking has failed to provide the contract between themselves and Tesco, containing relevant information which includes the necessary contractual written authority for the issue and enforcement of the Parking Charge Notice.

I put Highview Parking to strict proof to provide an unredacted, contemporaneous copy of the contract with the Landowner, which - to demonstrate standing and authority - must specifically state that Highview Parking can make contracts with drivers themselves and that they have full authority to pursue charges in court in their own name. A witness statement to the effect that a contract is in place will not be sufficient because it will not show which restrictions are to be enforced, what the times/dates/details of enforcement are. How will I know that the landowner contract allows Highview Parking to charge £70 for this particular contravention if the contract is not produced? Showing a piece of paper signed by someone who has never seen the actual contract, saying merely that Highview Parking can put up signs and 'issue parking charges' would not prove that this charge is within the contract nor will it show any standing of this site agent.

3) No creditor identity. The notice refers to Highview Parking LTD but It has not been disclosed exactly who is making the claim and in what capacity. Highview parking has failed to disclose exactly who is making the claim and in what capacity. The Notice to Keeper has not been properly given under POFA 2012, therefore there is no keeper liability.

The Notice I have received, as the registered owner of the vehicle, makes it clear that Highview Parking is relying on Schedule 4 of the Protection of Freedoms Act 2012. Highview Parking has failed to comply in the wording of their Notice to Keeper since they have failed to identify the ‘Creditor’. This may, in law, be Highview Parking or their client, their debt collecting agent, or the landowner or indeed some other party. Schedule 4 of the Act requires a Notice to Keeper to have the words to the effect that ‘The Creditor is.....”.

The wording of Paragraph 9(2)(h) of Schedule 4 of the Act does not just indicate that the creditor must be named/assumed, but “identified”. The owner of the vehicle is entitled to know the identity of the party with whom the driver has allegedly contracted. In failing to specifically identify the ‘Creditor’ in its Notice to Keeper, Highview Parking has failed to establish keeper liability. In this case, the NTK has not been correctly 'given' under POFA2012 and so it is a nullity. In a previous ruling, POPLA Assessor Matthew Shaw stated that the validity of a Notice to Keeper is 'fundamental to establishing liability' for a parking charge, stating: 'where a Notice is to be relied upon to establish liability it must, as with any statutory provision, comply with the Act.'

4) No contract. As stated in the BPA code 18.1 “You must use signs to make it easy...to find out what your terms and conditions are.”BPA code 18.2 states “Entrance signs play an important part in establishing a parking contract and deterring trespassers. Therefore, as well as the signs you must have telling drivers about the terms and conditions for parking, you must also have a standard form of entrance sign at the entrance to the parking area. Entrance signs must tell drivers that the car park is managed and that there are terms and conditions they must be aware of. Entrance signs must follow some minimum general principles and be in a standard format. The size of the sign must take into account the expected speed of vehicles approaching the car park, and it is recommended that you follow Department for Transport guidance on this.”

BPA code 18.3 states “Specific parking-terms signage tells drivers what your terms and conditions are, including your parking charges. You must place signs containing the specific parking terms throughout the site, so that drivers are given the chance to read them at the time of parking or leaving their vehicle. Keep a record of where all the signs are. Signs must be conspicuous and legible, and written in intelligible language, so that they are easy to see, read and understand.”

Unreadable signage breaches Appendix B of the BPA CoP which states that terms on entrance signs must be clearly readable without a driver having to turn away from the road ahead. This would include the signs being lit/reflective and repeated throughout the car park, with consistency of restrictions throughout. In this underground car park the entrance sign is very dimly lit (during any conditions) and positioned at a height requiring a driver to divert their attention considerably from the road ahead, making it not only unreasonable to expect, but potentially dangerous for a driver to read and understand the information whilst also negotiating down the steep incline into a busy underground car park with a concealed entrance.

The signage was not sufficiently prominent nor clearly worded and consideration did not flow from both parties, so there could not have been any contract formed. I have personally visited the site in question. I believe the signs and any core parking terms that the parking company are relying upon were too high, far too small, insufficiently distributed around the site, if existing at all. The operator has failed to provide any requested evidence of signage, maps or photos on the aforementioned points, specifically showing the height of the signs, where they are at the entrance, whether a driver still in a car can see and read them when deciding to drive in, and adequate distribution of ‘terms and conditions’ throughout the site.

5) The ANPR system is unreliable and neither synchronised nor accurate. The charge is founded entirely on two photos of my vehicle entering/leaving the car park at specific times. I put Highview Parking to strict proof that their ANPR system is not fundamentally flawed because of known issues such as missing checks and maintenance of the timer/cameras and the possibility of two visits being recorded as one. The Operator's proof must show checks relating to my case/vehicle. (The 'two visits recorded as one' problem is very common and is even mentioned on the BPA website as a known issue). The BPA says: ''As with all new technology, there are issues associated with its use: Repeat users of a car park inside a 24 hour period sometimes find that their first entry is paired with their last exit, resulting in an ‘overstay’. Operators are becoming aware of this and should now be checking all ANPR transactions to ensure that this does not occur.''

Since I am merely the registered keeper, I have no evidence to discount the above possibilities. Highview Parking has failed to show any parking photographs so they cannot say for certain that the car was not involved in non-parking related activity - e.g. queuing, nor can they show the car did not leave the site and return.

This could easily be a case of two visits, or if my vehicle was on site for the time shown, I suggest that it may well not have been 'parked' for more than 2 hours. Due to the site location, entry and exit is often into congested one-way traffic, this car park site frequently becomes gridlocked at peak times, resulting in long queuing periods on the site. Whether or not this occurred, there is an increased likelihood that this was the case, and evidence is required to show that the car was not queuing for a substantial period of time. I require Highview Parking to rebut these assertions.

I agree with the BPA that this ANPR technology has issues associated with its use. These also include (but are not limited to) synchronisation errors, buffering, faults with the timer, faults with one or other of the cameras, faults with the wireless signals and differences between the settings of the in/out clocks. The operator appears to use WIFI with an inherent delay through buffering, so "live" is not really "live". Hence without a synchronised time stamp there is no evidence that the image is ever accurate to the minute.

In addition, the BPA CoP contains the following in paragraph 21:
''You may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as you do this in a reasonable, consistent and transparent manner. Your signs at the car park must tell drivers that you are using this technology and what you will use the data captured by ANPR cameras for.''

Highview Parking fail to operate the system in a 'reasonable, consistent and transparent manner'. They place signs too high and are far too small to see on arrival and these are not adequately lit, so there is no opportunity for drivers in moving traffic at the entrance to be 'informed that this technology is in use and what the Operator will use the data captured by ANPR cameras for'. I contend that as well as being unreliable, this is a non-compliant ANPR system being merely a secret high-up spy camera - far from 'transparent' - unreasonably 'farming' the data from moving vehicles at the entrance & exit and neither 'managing, enforcing nor controlling parking' since the cameras are not concerned with any aspect of the actual parking spaces, nor any parking event at all.

This concludes my appeal.

ampersand

I'd retain the clear headings in bold for each rebuttal point. That's why they are there. You need to befriend the assessor with lay-out, initial impression, clarity on all levels from the off.

Use more para.s

I'd also remove your elements of opinion: this is not your parking event après tout:-) We understand how much you are putting into helping your friend, but this is not the place to exercise the protector instinct or Rumpole manquÉ in you.

e.g. omit 'merely', 'purely'[you mean 'solely'], all superfluous adverbs.

1. Include ''legal' before 'standing'.
I'd lose 'How will I know that the landowner contract allows Highview Parking to charge £70 for this particular contravention if the contract is not produced? Showing a piece of paper signed by someone who has never seen the actual contract, saying merely that Highview Parking can put up signs and 'issue parking charges' would not prove that this charge is within the contract nor will it show any standing of this site agent.' Redundant in view of your preceding para.

I, me, myself, have no place in these Appeals. Depersonalise, use 3rd person. 'The Claimant', 'the Appellant' always reads more strongly.

I do feel your personal bolt-ons point-by-point are not the way to go. That's where the strength of each is diluted and even offers comeback openings should the jackals be so inclined.

[STRIKE]'It has been made aware from[/STRIKE] Court rulings and previous POPLA adjudications make clear that the cost of running the business may not be included in these pre-estimates of loss'

Duplication here:
' The notice refers to Highview Parking LTD but It has not been disclosed exactly who is making the claim and in what capacity. Highview parking has failed to disclose exactly who is making the claim and in what capacity.'
#
op- less is more.
I have pared,re-ordered and tightened this section as a guide:

[STRIKE][STRIKE]Since I am merely the[/STRIKE]As registered keeper, I have no evidence to discount the above possibilities.[/STRIKE] Highview Parking has failed to show any parking photographs so they cannot say for certain that the car was not involved in non-parking related activity - e.g. queuing, nor can they show the car did not leave the site and return.

Duplicate visits are a frequent and recognised trigger for these parking event 'invoices.' - [if you must include this at all.]

[STRIKE]
This could easily be a case of two visits,[STRIKE] or if my vehicle was on site for the time shown, [/STRIKE]I suggest that it may well not have been 'parked' for more than 2 hours. [/STRIKE]

Congestion at this site is the norm. Entry and exit lay-out means traffic is often reduced to one-way, gridlocked at peak times. The Appellant requires Highview Parking to show that [reg.no.] was not queuing for a substantial period of time.

The BPA accepts that this ANPR technology is flawed, including, but not limited to:
synchronisation errors, buffering, faults with the timer, faults with one or other of the cameras, faults with the wireless signals and differences between the settings of the in/out clocks.

The operator appears to use WIFI with an inherent delay through buffering, so "live" is not really "live". Without a synchronised time stamp, there is no evidence that the image is ever accurate to the minute.

BPA CoP paragraph 21 states:...etc.

This would include the signs being lit, reflective and repeated throughout the car park, with consistency of restrictions throughout.
#
'[STRIKE]I have personally[/STRIKE][The Appellant visited the site in question. The only sign observed at this underground car park is ill-lit during any conditions. [ref.pic]
It is too high and too small for any driver to read and absorb at eye level, while advancing towards a darkened, tunnel-like entrance.[STRIKE]insufficiently distributed around the site[STRIKE], if existing at all.[/STRIKE]. [/STRIKE]

Positioned at such a height, if noticed at all, it requires a driver to divert his or her attention awkwardly from the road ahead, making it not only unreasonable to expect, but potentially dangerous. Certainly, negotiating a steep ramp down into a busy underground car park with a concealed entrance makes seeing, reading and understanding any ill-placed, ill-lit and otherwise non-compliant sign both unreasonable and potentially dangerous.

final para:
Highview Parking failed to operate the system in the required 'reasonable, consistent and transparent manner'.
There is no opportunity for drivers in moving traffic at the entrance to be 'informed that this technology is in use' and how the Operator will use the data captured by ANPR cameras. In fact, this non-compliant ANPR system is 'farming' data from moving vehicles at the entrance and exit, with the Claimant neither 'managing, enforcing nor controlling parking' since the cameras are not concerned with any aspect of the actual parking spaces, nor any parking event at all.

Will look in again later. Keep tweaking.