Birmingham Airport APCOA appeal

Royals18

Hi,

I apologise for another forum regarding this but all the responses I've seen this far advise not to mention the name of the driver however this has already been done in my appeal to APCOA stupidly.

My employer handed me the notice as the keeper of the company car so straight away I complained. The reason for my fine was:

I went to BHX to pick up my uncle from arrivals and was heading to the pick up/drop off (£1 for around 10 mins I believe). My boyfriend who was in the car with me as he was getting a train from International, got out of my car whilst i was stood still at a zebra crossing allowing someone to cross as he was going to miss his train.

I then proceeded to the drop off/pick up to pick up my uncle, paid for the parking and left the airport.

Although explaining I wasnt avoiding charges as i still went into the car park, a photo of someone crossing the road whilst my boyfriend got out and according to the times on the pictures I was stationary for less than 10 seconds, APCOA rejected my appeal and issued the exact same letter they do to all of those who have been in similar situations to me (no stopping in a non-desginated area, 20 signs that advise of this etc) so I won't post again unless required.

As I have inadvertently advised I was the driver, I am not sure how to structure my appeal to POPLA Airport.

Can you please advise?

Thank you

KeithP

Add the word PoPLA to your thread title and stick Birmingham Airport APCOA appeal POPLA into the forum's search facility.

You will find many appeal texts already written. Just adapt a likely one to your specifics.

Can you post your original appeal to APCOA here?

Redx

find a recent apcoa BHX popla appeal and remove all the POFA2012 keeper liability paragraphs etc, leaving in the issues of bylaws applying so its a penalty and not a parking charge , no contract , not the same as beavis , signage , any BPA CoP failures etc

Royals18

I will add that to the title once I have figures out how to do this!

My response is very amateur so sorry if this makes things harder to appeal:

I had a passenger in my car whom was catching a train from Birmingham international as I was also there to pick up a passenger. My passenger who was already in my car jumped out of the car whilst we were stood stationery waiting at a zebra crossing as they were going to miss their train. I then continued to proceed to the drop off/pick up car park at which point the barrier I was at was not working and I was advised to reverse and try the next machine which provided me a ticket. I then picked up my passenger from the car park, paid for the time I spent there and left. I did not purposely avoid going into a car park to drop someone off and I have paid for parking whilst there so I feel that this is very unfair as I did not stop to allow them out but to allow someone to cross a zebra crossing so I would like to appeal this fine. My car registration should be visible on the cameras entering the drop off/pick up zone however if you need flight
information from the passenger I picked up, I can provide this to you.

KeithP

No, I was not suggesting you change your thread title, just that you use the words of the title, together with the word popla, as a search argument.

Royals18

Hi,

From looking at ither forums i have devised this response. Can you check please as i have already admitted i was the driver so taken those points out.

Thank you

POPLA!Ref xxxxx
APCOA!Parking PCN no xxxxx
A notice to keeper was issued on 2018 and received by me (the driver of vehicle registration xxxxx) on 2018 for an alleged contravention of !!!8216;BREACH OF THE TERMS AND CONDITIONS OF USE!!!8217;!!!8217;. I am writing to you as the registered keeper and would be grateful if you would please consider my appeal for the following reasons.

1)!APCOA!not using POFA 2012 - Byelaws!
2) Airport Act 1986
3) Non-compliance with requirements and timetable set out in Schedule 4 of POFA 2012
4) Not relevant Land under POFA 2012; no registered keeper liability (ref!POPLA!case Steve Macallan 6062356150)
5) Misleading and unclear signage
6) No evidence of Landowner Authority - the operator is put to strict proof of full compliance with the BPA Code of Practice
7) Photo evidence appears doctored

1) From APCOA!!!8217;s rejection to my initial appeal, it appears that!APCOA!are attempting to claim the charge is liable to them under airport byelaws. I reject this and put them strictly to proof on which byelaw they claim is broken, and in any case, why this would result in an obligation to pay!APCOA.

2) Airport bylaws do not apply to any road to which the public have access, as they are subject to road traffic enactments.
Airport Act 1986
65 Control of road traffic at designated airports
(1) Subject to the provisions of this section, the road traffic enactments shall apply in relation to roads which are within a designated airport but to which the public does not have access as they apply in relation to roads to which the public has access.
Both the Airport Act and Airport byelaws say thatbyelaws only apply to roads to which road traffic enactments do not apply

3) If!APCOA!want to make use of the Keeper Liability provisions in Schedule 4 of POFA 2012 and!APCOA!have not issued and delivered a parking charge notice to the driver in the place where the parking event took place, your Notice to Keeper must meet the strict requirements and timetable set out in the Schedule (in particular paragraph 9). I have had no evidence that!APCOA!have complied with these BPA Code requirements for ANPR issued tickets so require them to evidence their compliance to!POPLA.!
The BPA code of practice also says '20.14 when you serve a Notice to Keeper, you must also include information telling the keeper the !!!8216;reasonable cause!!!8217; you had for asking the DVLA for their details.' The PCN does not provide this information; this does not comply with the BPA code point 20.14.!

4) Airport land is not 'relevant land' as it is already covered bystatutory bylaws and so is specifically excluded from 'keeper liability' under Schedule 4 of the Protection of Freedoms Act 2012. As I am the registered keeper I am not legally liable as this Act does not apply on this land. I put the Operator to strict proof otherwise if they disagree with this point and would require them to show evidence including documentary proof from the Airport Authority that this land is not already covered by bylaws.
POPLA!assessor Steve Macallan found in 6062356150 in September 2016 that land under statutory control cannot be considered !!!8216;relevant land!!!8217; for the purposes of POFA 2012.!
!!!8216;As the site is not located on !!!8216;relevant land!!!8217;, the operator is unable to rely on POFA 2012 in order to transfer liability to the hirer. Additionally, as I am not satisfied the appellant was the driver, I am unable to conclude that the operator issued the PCN correctly, and I must allow this appeal.!!!8217;

5) The alleged contravention, according to!APCOA, is in 'breach of the terms and conditions of use of the Airport road infrastructure and signs are clearly displayed'. It would however appear that signage at this location do not comply with road traffic regulations or their permitted variations and as such are misleading - they are unable to be seen by a driver and certainly could not be read without stopping, and therefore do not comply with the BPA code of practice.!APCOA!are required to show evidence to the contrary.
I would draw the assessor's attention to the 'No Stopping Zones' section of the Chief Adjudicator's First Annual!POPLA!Report 2013: "It is therefore very important that any prohibition is clearly marked; bearing in mind that such signage has to be positioned, and be of such a size, as to be read by a motorist without having to stop to look at it. Signs on red routes, unlike those indicating most parking restrictions, are generally positioned to face oncoming traffic, rather than parallel to it."
I contend that in order for a motorist to read and understand the content of the signage they would need to stop to study it. Any attempt to read and understand the signage whilst driving at the prevailing speed limit would compromise their ability to drive safely. It is clearly unreasonable for a motorist to have to breach the terms and conditions of use of the Airport road infrastructure in order to acquaint themselves with those terms and conditions.
Furthermore, I contend that APCOA!!!8217;s assertion that no stopping is allowed at any time on a red route is inconsistent with motorists!!!8217; obligations under the Highway Code. There are numerous circumstances in which a motorist would be obliged to stop; for example following a road traffic accident, break down, obstructions or pedestrians crossing. The photographic evidence shows that the vehicle in question had stopped to allow a predestrian to cross at a zebra crossing.

6) As this operator does not have proprietary interest in the land then I require that they produce an unredacted copy of the contract with the landowner. The contract and any 'site agreement' or 'User Manual' setting out details including exemptions - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights - is key evidence to define what this operator is authorised to do and any circumstances where the landowner/firms on site in fact have a right to cancellation of a charge. It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is also authorised to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only).
Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules. A witness statement might in some cases be accepted by!POPLA!but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement.!
Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic information such as the land boundary and bays where enforcement applies/does not apply. Not forgetting evidence of the various restrictions which the landowner has authorised can give rise to a charge and of course, how much the landowner authorises this agent to charge (which cannot be assumed to be the sum in small print on a sign because template private parking terms and sums have been known not to match the actual landowner agreement).!
Paragraph 7 of the BPA CoP defines the mandatory requirements and I put this operator to strict proof of full compliance:
6.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.
6.3 The written authorisation must also set out:
a the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
b any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
c any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
d who has the responsibility for putting up and maintaining signs
e the definition of the services provided by each party to the agreement

7) I would also bring into question the authenticity of the photographs taken of the vehicle !!!8211; most notably the time stamps and location coordinates. By close examination of the photographs, the details (time, location, direction) are added as a black overlay box on-top of the photos in the upper right hand corner. It is well within the realms of possibility for even an amateur to use free photo-editing software to add these black boxes and text with authentic looking Meta data. Not only is this possible, but this practice has even been in use by UKPC, who were banned by the DVLA after it emerged.
I would challenge!APCOA!to prove that a stationary, highly advanced camera was used to generate these photos (including viewing direction, camera location etc.). I would also challenge!APCOA!that they possess the technology to generate these precise types of coordinates, as they have been applied to the photo in such an amateurish way (there are much more sophisticated ways of hardcoding photo data).

I therefore request that!POPLA!uphold my appeal and cancel this PCN.

Umkomaas

i have already admitted i was the driver so taken those points out.

If this has already been admitted, then all the stuff you've put in about 'not relevant land' and 'no keeper liability' is irrelevant and should be removed from your draft.

I've only skim read the draft as the formatting is awful and the text is riddled with random exclamation marks and other hieroglyphics making it very difficult to read in detail.

In order to help so many people who come to the forum daily, we have to read hundreds and hundreds of text blocks. Poor formatting literally gives me headache when reading, so there's only one way I know to avoid the pain. :cool:

Coupon-mad

Your first appeal without researching it first (very common but awful error) threw in the bin, the 100% win you were guaranteed as a company car hirer/lessee, so you can't use points 1 - 4 at all now.

Next time, realise that you have 100% win as a hirer/lessee against almost any PPC - but NEVER talk about who was driving, or the story of what happened.

You should add a point about 'grace periods' from a POPLA appeal about that (search!).

And add the usual one about ANPR ICO Surveillance Camera rules and excessive use and processing of data 24/7 (again, found in 20 seconds with 2 keywords).

Royals18

Hi,

Apologies for the delay - was trying to find the correct points to use and personal issues also didn't help!

Can you please advise if the below is okay to send? It won't let me post links in case you are wondering why there are incomplete lines.



POPLA Ref xxxxx
APCOA Parking PCN no xxxxx
A notice to keeper was issued on 2018 and received by me (the driver of vehicle registration xxxxx) on 2018 for an alleged contravention of BREACH OF THE TERMS AND CONDITIONS OF USE. I am writing to you as the registered keeper and would be grateful if you would please consider my appeal for the following reasons.


1) Airport Act 1986
2) Misleading and unclear signage
3) No evidence of Landowner Authority - the operator is put to strict proof of full compliance with the BPA Code of Practice
4) Photo evidence appears doctored
5) The minimum grace period was not allowed by the operator
6) Data Protection Act and BPA Code of Practice breach

1) Airport bylaws do not apply to any road to which the public have access, as they are subject to road traffic enactments.

Airport Act 1986
65 Control of road traffic at designated airports
(1) Subject to the provisions of this section, the road traffic enactments shall apply in relation to roads which are within a designated airport but to which the public does not have access as they apply in relation to roads to which the public has access.
Both the Airport Act and Airport byelaws say thatbyelaws only apply to roads to which road traffic enactments do not apply

2) I note that within the Protection of Freedoms Act (POFA) 2012 it discusses the clarity that needs to be provided to make a motorist aware of the parking charge. Specifically, it requires that the driver is given 'adequate notice' of the charge. POFA 2012 defines 'adequate notice' as follows:

''(3) For the purposes of sub-paragraph (2) 'adequate notice' means notice given by: (a) the display of one or more notices in accordance with any applicable requirements prescribed in regulations under paragraph 12 for, or for purposes including, the purposes of sub-paragraph (2); or (b) where no such requirements apply, the display of one or more notices which: (i) specify the sum as the charge for unauthorised parking; and (ii) are adequate to bring the charge to the notice of drivers who park vehicles on the relevant land''.

Even in circumstances where POFA 2012 does not apply, I believe this to be a reasonable standard to use when making my own assessment, as appellant, of the signage in place at the location. Having considered the signage in place at this particular site against the requirements of Section 18 of the BPA Code of Practice and POFA 2012, I am of the view that the signage at the site - given the minuscule font size of the £100, which is illegible in most photographs and does not appear at all at the entrance - is NOT sufficient to bring the parking charge (i.e. the sum itself) to the attention of the motorist.

There was no contract nor agreement on the 'parking charge' at all. It is submitted that the driver did not have a fair opportunity to read about any terms involving this huge charge, which is out of all proportion and not saved by the dissimilar 'ParkingEye Ltd v Beavis' case.

In the Beavis case, which turned on specific facts relating only to the signs at that site and the unique interests and intentions of the landowners, the signs were unusually clear and not a typical example for this notorious industry. The Supreme Court were keen to point out the decision related to that car park and those facts only:

Www

In the Beavis case, the £85 charge itself was in the largest font size with a contrasting colour background and the terms were legible, fairly concise and unambiguous. There were 'large lettering' signs at the entrance and all around the car park, according to the Judges.

Here is the 'Beavis case' sign as a comparison to the signs under dispute in this case:

blogspot

This case, by comparison, does not demonstrate an example of the 'large lettering' and 'prominent signage' that impressed the Supreme Court Judges and swayed them into deciding that in the specific car park in the Beavis case alone, a contract and 'agreement on the charge' existed.

Here, the signs are sporadically placed, indeed obscured and hidden in some areas. They are unremarkable, not immediately obvious as parking terms and the wording is mostly illegible, being crowded and cluttered with a lack of white space as a background. It is indisputable that placing letters too close together in order to fit more information into a smaller space can drastically reduce the legibility of a sign, especially one which must be read BEFORE the action of parking and leaving the car.

It is vital to observe, since 'adequate notice of the parking charge' is mandatory under the POFA Schedule 4 and the BPA Code of Practice, these signs do not clearly mention the parking charge which is hidden in small print (and does not feature at all on some of the signs). Areas of this site are unsigned and there are no full terms displayed - i.e. with the sum of the parking charge itself in large lettering - at the entrance either, so it cannot be assumed that a driver drove past and could read a legible sign, nor parked near one.

This case is more similar to the signage in POPLA decision 5960956830 on 2.6.16, where the Assessor Rochelle Merritt found as fact that signs in a similar size font in a busy car park where other unrelated signs were far larger, was inadequate:

''the signage is not of a good enough size to afford motorists the chance to read and understand the terms and conditions before deciding to remain in the car park. [...] In addition the operators signs would not be clearly visible from a parking space [...] The appellant has raised other grounds for appeal but I have not dealt with these as I have allowed the appeal.''

From the evidence I have seen so far, the terms appear to be displayed inadequately, in letters no more than about half an inch high, approximately. I put the operator to strict proof as to the size of the wording on their signs and the size of lettering for the most onerous term, the parking charge itself.

The letters seem to be no larger than .40 font size going by this guide:

archive.mozilla

As further evidence that this is inadequate notice, Letter Height Visibility is discussed here:

signazon

''When designing your sign, consider how you will be using it, as well as how far away the readers you want to impact will be. For example, if you are placing a sales advertisement inside your retail store, your text only needs to be visible to the people in the store. 1-2' letters (or smaller) would work just fine. However, if you are hanging banners and want drivers on a nearby highway to be able to see them, design your letters at 3' or even larger.''

...and the same chart is reproduced here:

.ebay

''When designing an outdoor sign for your business keep in mind the readability of the letters. Letters always look smaller when mounted high onto an outdoor wall''.

''...a guideline for selecting sign letters. Multiply the letter height by 10 and that is the best viewing distance in feet. Multiply the best viewing distance by 4 and that is the max viewing distance.''

So, a letter height of just half an inch, showing the terms and the 'charge' and placed high on a wall or pole or buried in far too crowded small print, is woefully inadequate in an outdoor car park. Given that letters look smaller when high up on a wall or pole, as the angle renders the words less readable due to the perspective and height, you would have to stand right in front of it and still need a stepladder (and perhaps a torch and/or magnifying glass) to be able to read the terms.

Under Lord Denning's Red Hand Rule, the charge (being 'out of all proportion' with expectations of drivers in this car park and which is the most onerous of terms) should have been effectively: 'in red letters with a red hand pointing to it' - i.e. VERY clear and prominent with the terms in large lettering, as was found to be the case in the car park in 'Beavis'. A reasonable interpretation of the 'red hand rule' and the 'signage visibility distance' tables above and the BPA Code of Practice, taking all information into account, would require a parking charge and the terms to be displayed far more transparently, on a lower sign and in far larger lettering, with fewer words and more 'white space' as background contrast. Indeed in the Consumer Rights Act 2015 there is a 'Requirement for transparency':

(1) A trader must ensure that a written term of a consumer contract, or a consumer notice in writing, is transparent.
(2) A consumer notice is transparent for the purposes of subsection (1) if it is expressed in plain and intelligible language and it is legible.

The Beavis case signs not being similar to the signs in this appeal at all, I submit that the persuasive case law is in fact 'Vine v London Borough of Waltham Forest [2000] EWCA Civ 106' about a driver not seeing the terms and consequently, she was NOT deemed bound by them.

This judgment is binding case law from the Court of Appeal and supports my argument, not the operator's case:

Bailii

This was a victory for the motorist and found that, where terms on a sign are not seen and the area is not clearly marked/signed with prominent terms, the driver has not consented to - and cannot have 'breached' - an unknown contract because there is no contract capable of being established. The driver in that case (who had not seen any signs/lines) had NOT entered into a contract. The recorder made a clear finding of fact that the plaintiff, Miss Vine, did not see a sign because the area was not clearly marked as 'private land' and the signs were obscured/not adjacent to the car and could not have been seen and read from a driver's seat before parking.

So, for this appeal, I put this operator to strict proof of where the car was parked and (from photos taken in the same lighting conditions) how their signs appeared on that date, at that time, from the angle of the driver's perspective. Equally, I require this operator to show how the entrance signs appear from a driver's seat, not stock examples of 'the sign' in isolation/close-up. I submit that full terms simply cannot be read from a car before parking and mere 'stock examples' of close-ups of the (alleged) signage terms will not be sufficient to disprove this.

3) As this operator does not have proprietary interest in the land then I require that they produce an unredacted copy of the contract with the landowner.

The contract and any 'site agreement' or 'User Manual' setting out details - such as any 'genuine customer' or 'genuine resident' exemptions or any site occupier's 'right of veto' charge cancellation rights, and of course all enforcement dates/times/days, and the boundary of the site - is key evidence to define what this operator is authorised to do, and when/where.

It cannot be assumed, just because an agent is contracted to merely put some signs up and issue Parking Charge Notices, that the agent is authorised on the material date, to make contracts with all or any category of visiting drivers and/or to enforce the charge in court in their own name (legal action regarding land use disputes generally being a matter for a landowner only).

Witness statements are not sound evidence of the above, often being pre-signed, generic documents not even identifying the case in hand or even the site rules. A witness statement might in some cases be accepted by POPLA but in this case I suggest it is unlikely to sufficiently evidence the definition of the services provided by each party to the agreement.

Nor would it define vital information such as charging days/times, any exemption clauses, grace periods (which I believe may be longer than the bare minimum times set out in the BPA CoP) and basic but crucial information such as the site boundary and any bays where enforcement applies/does not apply. Not forgetting evidence of the only restrictions which the landowner has authorised can give rise to a charge, as well as the date that the parking contract began, and when it runs to, or whether it runs in perpetuity, and of course, who the signatories are: name/job title/employer company, and whether they are authorised by the landowner to sign a binding legal agreement.

Paragraph 7 of the BPA CoP defines the mandatory requirements and I put this operator to strict proof of full compliance:

7.2 If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.

7.3 The written authorisation must also set out:

a the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
b any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
c any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
d who has the responsibility for putting up and maintaining signs
e the definition of the services provided by each party to the agreement

4) I would also bring into question the authenticity of the photographs taken of the vehicle; most notably the time stamps and location coordinates. By close examination of the photographs, the details (time, location, direction) are added as a black overlay box on-top of the photos in the upper right hand corner. It is well within the realms of possibility for even an amateur to use free photo-editing software to add these black boxes and text with authentic looking Meta data. Not only is this possible, but this practice has even been in use by UKPC, who were banned by the DVLA after it emerged.

I would challenge APCOA to prove that a stationary, highly advanced camera was used to generate these photos (including viewing direction, camera location etc.). I would also challenge APCOA that they possess the technology to generate these precise types of coordinates, as they have been applied to the photo in such an amateurish way (there are much more sophisticated ways of hardcoding photo data).

5) The vehicle stopped at a zebra crossing at 19:15:19 and was moving again at 19:15:27. British Parking Association Code of Practice 13.1 - 13.4 states:

13 Grace periods

13.1 Your approach to parking management must allow a driver who enters your car park but decides not to park, to leave the car park within a reasonable period without having their vehicle issued with a parking charge notice.

13.2 You should allow the driver a reasonable grace period in which to decide if they are going to stay or go. If the driver is on your land without permission you should still allow them a grace period to read your signs and leave before you take enforcement action.

13.3 You should be prepared to tell us the specific grace period at a site if our compliance team or our agents ask what it is.

13.4 You should allow the driver a reasonable period to leave the private car park after the parking contract has ended, before you take enforcement action. If the location is one where parking is normally permitted, the Grace Period at the end
of the parking period should be a minimum of 10 minutes.

6) This Claimant uses ANPR camera systems to process data but fails to comply with the Information Commissioner's 'Data Protection Code of Practice for Surveillance Cameras and Personal Information' (the ICO Code). This is both a specific Data Protection and BPA Code of Practice breach.

6.1. The ICO Code applies to all ANPR systems, and states that the private sector is required to follow it, in order to meet its legal obligations as a data processor. Members of the BPA are required to comply fully with the Data Protection Act (DPA) and all ICO rules and guidelines, as a pre-requisite of being able to use the DVLA KADOE system and in order to enforce parking charges on private land.

6.2. The Claimant's failures to comply include, but are not limited to the following, and the Claimant is put to strict proof otherwise on all counts:

i) Lack of an initial privacy impact assessment, and

ii) Lack of an evaluation of proportionality and necessity, considering concepts that would impact upon fairness under the first data protection principle, and

iii) Failure to regularly evaluate whether it was necessary and proportionate to continue using ANPR, together with an iPad as a secondary data processing system at this site, as opposed to a less privacy-intrusive method of parking enforcement (such as 'light touch' enforcement only at busy times, or manning the car park with a warden in order to consider the needs of genuine patrons), and

iv) Failure to consider the number of complaints from the Odeon and other businesses, which would have alerted this Claimant to the fact that their 'iPad system' and woeful sign was not being seen by all genuine patrons and was therefore a wholly inappropriate method of data capture, which was unreliable at best and negligent (or even deliberately misleading) at worst, being the main cause of unfair parking charges against Odeon patrons, and

v) Failure to prominently inform a driver in large lettering on clear signage, of the purpose of the ANPR system and the iPad system and how the data captured on both would be used, and

vi) Lack of the 'Privacy Notice' required to deliver mandatory information about an individual's right of subject access, under the DPA. At no point has the Defendant been advised how to apply for, and what a data subject's rights are, to obtain all images and data held via a Subject Access Request from the Claimant.

6.3. This Claimant has therefore failed to meet its legal obligations and has breached principle 1 (at least) of the DPA, as well as the BPA Code of Practice.

I therefore request that POPLA uphold my appeal and cancel this PCN.

Coupon-mad

Remove the Signazon & Ebay links that no longer work and the words about those.

Royals18

Okay, thank you Coupon Mad. Is it okay to send otherwise?