Britania Parking PCN - Bournemouth

Nonconform

also, from researching the forum, i was going to add this at the beginning of the appeal:

I received a Notice to Keeper (NtK) from Britannia Parking regarding a parking charge of £100.

In my first appeal to Britannia directly I quite clearly requested that they provide me:
• “all photos taken, a clear image of the signage and an explanation of the allegation”

I can confirm that no such photos were received. I was sent some undated photos of signage that does not verify neither the date/time, neither weather conditions, nor light conditions of the alleged contravention.

No photos of the vehicle were proffered despite my request.

Both these omissions by Britannia can only be viewed as an attempt to hinder any appeal of the alleged contravention and as such put me at an unfair disadvantage when trying to appeal this alleged contravention.

Another point which I would like to put before entering into greater detail of my legal standing with this alleged contravention is the following regarding the signage. On the photos that were received by Britannia, it quite clearly states “Parking Charge Notice may be issued to all vehicles which:”
Now that phrase alone is completely ambiguous, as the use of the word ”may” would indicate that there are times when a Parking Charge Notice “may not” be issued.

If a Parking Charge Notice is a definite outcome of a parking contravention, then the word “WILL” should replace the word “MAY”.

As such the signage is ambiguous and misleading. It would then seem to be a very subjective decision making process – can Britannia provide their rationale for this?

Can Britannia provide a clear and comprehensive list of circumstances of when a Parking Charge Notice “may not” be issued?

As the registered keeper I wish to refute these charges on the following grounds:

Nonconform

and i added a another point at the end of the appeal as follows:

The Signs Fail to Transparently Warn Drivers of what the ANPR Data will be used for

The signs fail to transparently warn drivers of what the ANPR data will be used for which breaches the BPA Code of Practice and the Consumer Protection from Unfair Trading Regulations 2008 due to inherent failure to indicate the 'commercial intent' of the cameras.

Paragraph 21.1 of the BPA Code of Practice advises operators that they may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as they do this in a reasonable, consistent and transparent manner. The Code of Practice requires that car park signs must tell drivers that the operator is using this technology and what it will use the data captured by ANPR cameras for.

Britannia Parking signs do not comply with these requirements because these car park signage failed to accurately explain what the ANPR data would be used for, which is a 'failure to identify its commercial intent', contrary to the BPA CoP and Consumer law.

Britannia Parking main sign states: “Camera Controlled Pay on Arrival”;

Other signs state: “Car park monitored by ANPR systems”

Specifically missing from this sentence is the vital information that these camera images would be used in order to issue Parking Charge Notices. There is absolutely no suggestion in the sentence above that the cameras are in any way related to Parking Charge Notices. The only reference to Parking Charge Notices on Britannia Parking sign makes no mention of Parking Charge Notices being issued as a result of images captured by the ANPR cameras.

In circumstances where the terms of a notice are not negotiable (as is the case with the car park signage, which is a take-it-or-leave-it contract) and where there is any ambiguity or contradiction in those terms, the rule of contra proferentem shall apply against the party responsible for writing those terms.

This is confirmed within the Consumer Rights Act 2015 including: Paragraph 68: 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.

and Paragraph 69:

Contract terms that may have different meanings:

(1) If a term in a consumer contract, or a consumer notice, could have different meanings, the meaning that is most favourable to the consumer is to prevail.

Withholding material information from a consumer about the commercial (not security) purpose of the cameras would be considered an unfair term under The Consumer Protection from Unfair Trading Regulations 2008 because the operator 'fails to identify its commercial intent':

hxxp://www.legislation.gov.uk/uksi/2008/1277/contents/made

Misleading omissions: 6. - (1) ''A commercial practice is a misleading omission if, in its factual context, taking account of the matters in paragraph (2)

(a) the commercial practice omits material information,

(b) the commercial practice hides material information,

(c) the commercial practice provides material information in a manner which is unclear, unintelligible, ambiguous or untimely, or

(d) the commercial practice fails to identify its commercial intent, unless this is already apparent from the context, and as a result it causes or is likely to cause the average consumer to take a transactional decision he would not have taken otherwise.''

It is far from 'apparent' that a camera icon means a car's data is being harvested for commercial purposes of charging in a car park. A camera icon suggests CCTV is in operation for security within the car park.

Nonconform

Hi Coupon-Mad following your advice and comment:

And why is this (below) buried and impossible to read near the bottom, hidden in a long point about something else? Surely this should be your first point on its own, with an embedded image from GoogleStreetView or your own photos of the exit as proof that both images just show the car manoeuvring at the EXIT?

i have created a new point 1. Are you ok to review it please:

---

1. No Evidence of Period Parked – NTK does not meet PoFA 2012 requirements

The BPA Code of Practice point 20.5a stipulates that:

"When issuing a parking charge notice you may use photographs as evidence that a vehicle was parked in an unauthorized way. The photographs must refer to and confirm the incident which you claim was unauthorized. A date and timestamp should be included on the photograph. All photographs used for evidence should be clear and legible and must not be retouched or digitally altered."

The images included on the NtK contain two close-up license plate images and two images of the car manoeuvring at the exit of the car park.

Images contained on the NtK:
hxxps://postimg.cc/Wt4bkzfM

None of the images contain a time and date stamp and the second image of the license plate is a duplication of the first image. These images are taken of the exit of the car park. There are no images of the car using the entrance to the car park. Contrary to the mandatory provisions of the BPA Code of Practice, there is no record to show that the vehicle was parked versus attempting to read the terms and conditions before deciding against parking/entering into a contract.

The images captured by Britannia Parking ANPR are quite possibly of two separate visits/events captured at the car park EXIT at different times of the day. In other words, the ANPR may well have recorded images of the car entering the EXIT, leaving and then re-entering the car park EXIT at a later time.

Any vehicle manoeuvring around the EXIT of the car park will be captured by the ANPR. Britannia Parking, however, does not provide any direct evidence of its alleged violation. The operator's photos do not show an entrance image at all. A car shown facing the camera at the EXIT is just that, a car manoeuvring at the EXIT. It is not within the gift of Britannia Parking to substitute “entry/exit” or “length of stay” in place of the POFA requirement - “period of parking” - and hold the keeper liable as a result.

By virtue of the nature of an ANPR system recording only entry and exit times, Britannia Parking are not able to definitively state the period of parking. I require Britannia Parking to provide evidence to show the vehicle in question was parked on the date/time (for the duration claimed) and at the location stated in the NtK.

Image showing Britannia Parking car park exit from outside the car park:
hxxps://postimg.cc/hz2DYRhz

Note the lack of visible signage from the driver’s point of view when entering the car park this way.

Image showing Britannia Parking car park exit from inside the car park:
hxxps://postimg.cc/62W6zp6x

Image showing available manoeuvring space after driving into Britannia Parking car park EXIT:
hxxps://postimg.cc/HJCkctfx

Note the two yellow railings inside the car park on the left beyond the gate, match the two railings depicted on the NtK ANPR images showing where the car is in relation to the exit.

If the driver of a car which has entered the car park from this EXIT for whatever reason and immediately decides to leave, it would be necessary to drive further into the car park to clear the yellow barriers, before manoeuvring to turn round and leave by the same EXIT.

For clarity an image of the entrance to this car park is shown below. Comparing this against the car park EXIT images and ANPR images above it is clear that the ANPR images show the vehicle at the EXIT only.

Image of Car Park Entrance:
hxxps://postimg.cc/ts6g4cvw

Two exit photos are not evidence of anything which can pass as the 'single parking event' that POFA would allow for 'keeper liability' to be established. These images cannot be used as confirmation of the incident that Britannia Parking claim was unauthorised.

PoFA 2012 Schedule 4 paragraph 9 refers at numerous times to the “period of parking”. Most notably, paragraph 9(2)(a) requires the NtK to: “specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;”

Britannia Parking’s NtK simply claims that the vehicle “entered at XX:XX and departed at XX:XX”. At no stage does Britannia Parking explicitly specify the “period of parking to which the notice relates”, as required by POFA 2012.

Image of NtK issued to the Keeper:
hxxps://postimg.cc/bSdycV26

Britannia Parking uses ANPR (while failing to comply with the data protection 'ICO Code of Practice' applicable to ANPR) to capture images of vehicles entering and leaving the area to calculate their length of stay. Britannia Parking have not produced any images of the car entering the car park by use of the entrance or parking for a sustained period of time.

As a result, I require Britannia Parking to produce evidence of the original images containing the required date and time stamp and images showing the car is actually parked in the location stated rather than just manoeuvring in and out of the exit. Given the view of the public road seen in the image above, failing to produce such evidence would indicate the Britannia Parking has been using ANPR to engage random license plate collection of all vehicles manoeuvring in and out of the exit and send PCNs with the aim to extract penalty.

Recent investigation (27 Apr 2018) by the BBC hxxps://www.bbc.co.uk/news/business-43912327 shows that the private parking industry is unregulated and does not have any accountability. Various cases show the industry’s priority is maximizing the penalty received from the motorist without due regard to the integrity of the evidence. Private parking operators are financially incentivized not to use the original image as evidence, but putting partial evidence 21 together to generate a case biased towards generating a penalty fee. Based on the fact above, I require Britannia Parking to produce strong evidence, audited by qualified third party, to prove that its process is not biased to suit its financial objective.

Nonconform

Also here is the whole appeal as it stands:

1) No Evidence of Period Parked / NTK images do not meet BPA Code of Practice or PoFA 2012 requirements

2) The signs in this car park are not prominent, clear or legible from all parking spaces and there is insufficient notice of the sum of the parking charge itself

3) The operator has not shown that the individual who it is pursuing is in fact the driver who may have been potentially liable for the charge

4) No evidence of Landowner Authority - the operator is put to strict proof of full compliance with the BPA Code of Practice

5) The Notice To Keeper PCN was not properly issued because the alleged contravention was stated as “Failed to make a valid payment” when in fact a payment was made.

6) Grace Period: BPA Code of Practice – non-compliance

7) Failure to comply with the data protection 'ICO Code of Practice' applicable to ANPR

8) The Signs Fail to Transparently Warn Drivers of what the ANPR Data will be used for


Points 2,3 & 4 are well known to you.

Nonconform

Points 5,6,7 & 8 look like this:

5. The Notice To Keeper (NtK) PCN was not properly issued because the alleged contravention was stated as “Failed to make a valid payment” when in fact a payment was made.

The NtK issued by Britannia Parking alleged that the contravention was “Failed to make valid payment”. After disputing the PCN with Britannia Parking, they subsequently issued a reply rejecting the appeal stating: “The Parking Charge Notice was issued to the vehicle because the pay and display ticket had expired”, admitting that they got the contravention wrong on the NtK. Therefore the driver did not “fail to make a valid payment”. Britannia have offered no proof to me, the appellant, of either of these allegations and regardless, the NtK was not properly issued with a correct & consistent contravention.

6. Grace Period: BPA Code of Practice – non-compliance

The BPA’s Code of Practice states (13) that there are two grace periods: one at the end (of a minimum of 10 minutes) and one at the start.
BPA’s Code of Practice (13.1) states that:

“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.”

BPA’s Code of Practice (13.2) states that:

“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.”

BPA’s Code of Practice (13.4) states that:

“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.”

BPA’s Code of Practice (18.5) states that:

“If a driver is parking with your permission, they must have the chance to read the terms and conditions before they enter into the contract with you. If, having had that opportunity, they decide not to park but choose to leave the car park, you must provide them with a reasonable grace period to leave, as they will not be bound by your parking contract.”

The BPA Code of Practice (13.4) clearly states that the Grace Period to leave the car park should be a minimum of 10 minutes. Whilst 13.4 does not apply in this case (it should be made clear - a contract was never entered in to), it is reasonable to suggest that the minimum of 10 minutes grace period stipulated in 13.4 is also a “reasonable grace period” to apply to 13.1 and 13.2 of the BPA’s Code of Practice.

Kelvin Reynolds, Head of Public Affairs and Policy at the British Parking Association (BPA):

“The BPA’s guidance specifically says that there must be sufficient time for the motorist to park their car, observe the signs, decide whether they want to comply with the operator’s conditions and either drive away or pay for a ticket.” “No time limit is specified. This is because it might take one person five minutes, but another person 10 minutes depending on various factors, not limited to disability.”

Recently (late November 2017) there was a not dissimilar POPLA Appeal (versus ParkingEye – Tower Road, Newquay) which was successful on the grounds that the assessor believed 11 minutes was a “reasonable grace period” and that “by seeking alternate parking arrangements, the appellant has demonstrated that he did not accept the conditions of the parking contract.”

Finally, some 3 years ago years ago, on 30th July 2015, the minutes of the Professional Development & Standards Board meeting show that it was formally agreed by the Board (of BPA members and stakeholders) that the minimum grace period would be changed in 13.4 of the BPA Code of Practice to read 'a minimum of eleven minutes':

“Implications of the 10 minute grace period were discussed and the Board agreed with suggestion by AH that the clause should comply with DfT guidelines in the English book of by-laws to encourage a single standard. Board agreed that as the guidelines state that grace periods need to exceed 10 minutes clause 13.4 should be amended to reflect a mandatory 11 minute grace period.”

The recommendation reads:

“Reword Clause 13.4 to ‘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 11 minutes.”
(Source: hxxp://www.britishparking.co.uk/write/Documents/Meeting%20Notes/Governance/20150730_PDandS_Board_Action_Notes.pdf)

This shows that the intention of stating vaguely: 'a minimum of ten minutes' in the current BPA CoP (not a maximum - a minimum requirement) means to any reasonable interpretation that seconds are de minimis and therefore not taken into account – certainly an allegation of under eleven minutes is perfectly reasonable.

As stated earlier in this section, whilst 13.4 does not apply in this case (as a contract was never entered in to), it is not unreasonable to suggest that clarification of this time period in relation to 13.4 also goes some way to clarifying the terms “reasonable period” and “reasonable grace period” stated in 13.1 and 13.2 respectively of the BPA’s Code of Practice.

If the BPA feel “a minimum of 11 minutes” is a reasonable time period to leave a car park after a period of parking, it stands to reason that at least the same period of time is reasonable to also enter a car park, locate (and read) terms and conditions (in this case in the dark with no lighting), decide not to enter into a contract and then leave the car park.

Britannia Parking claim that the 2 hour ticket purchased for my vehicle had expired and that the vehicle was recorded entering the car park at 16:13 and leaving the car park at XX:XX.

Firstly, no evidence was included to support their claim of the ticket purchase and expiry time, and secondly BPA’s CoP states that the grace period at the end of the parking period should be a minimum of 10 minutes. This implies that it may take longer than 10 minutes to exit the car park but this does not amount to an overstay on the period of time on the ticket purchased. Nor does it take into account that if the car entered the car park at XX:XX, a justifiable period of time would be expected to find a space, park in it, exit the vehicle and make a purchase of the ticket after reading the tariffs on the pay machine. Taking this into account and adding the time allowed for the Grace period allowed then it would not be unreasonable to say that if the car exited the car park at XX:XX, the Grace Period was still valid.

Moreover, there is evidence that suggests this was more than one visit, as both images in fact show the car at the exit.

POPLA Assessors must look at the evidence to disprove and disregard your so-called Sector expert's lie that there is only one overall grace period once a person decides to stay, thereby somehow wiping out the observation period as if it never existed! The BPA CoP shows this is not true, as does BPA Director of Policy and Public Affairs, Kelvin Reynolds' official Trade Body article about 'Observation periods' and 'Grace periods' being two separate periods that must be applied separately:

hxxps://www.britishparking.co.uk/News/good-car-parking-practice-includes-grace-periods

Kelvin Reynolds, Head of Public Affairs and Policy at the British Parking Association (BPA) says there is a difference between ‘grace’ periods and ‘observation’ periods in parking and that good practice allows for this.

“An observation period is the time when an enforcement officer should be able to determine what the motorist intends to do once in the car park.”

“The BPA’s guidance defines the ‘grace period’ as the time allowed after permitted or paid-for parking has expired but before any kind of enforcement takes place.''

I believe that Britannia Parking are in breach of the BPA Code of Practice and are unjustified in issuing the PCN.

7. Failure to comply with the data protection 'ICO Code of Practice' applicable to ANPR (no information about SAR rights, no privacy statement, no evaluation to justify 24/7 ANPR enforcement at this site is fair and proportionate) - A serious BPA CoP breach

BPA’s Code of Practice (21.4) states that:

“It is also a condition of the Code that, if you receive and process vehicle or registered keeper data, you must:
• be registered with the Information Commissioner
• keep to the Data Protection Act
• follow the DVLA requirements concerning the data
• follow the guidelines from the Information Commissioner’s Office on the use of CCTV and ANPR cameras, and on keeping and sharing personal data such as vehicle registration marks.”
The guidelines from the Information Commissioner’s Office that the BPA’s Code of Practice (21.4) refers to is the CCTV Code of Practice found at: hxxps://ico.org.uk/media/1542/cctv-code-of-practice.pdf

The ICO’s CCTV Code of Practice makes the following assertions:

“This code also covers the use of camera related surveillance equipment including:
• Automatic Number Plate Recognition (ANPR);”

“the private sector is required to follow this code to meet its legal obligations under the DPA. Any organization using cameras to process personal data should follow the recommendations of this code.”

“If you are already using a surveillance system, you should regularly evaluate whether it is necessary and proportionate to continue using it.”

“You should also take into account the nature of the problem you are seeking to address; whether a surveillance system would be a justified and an effective solution, whether better solutions exist, what effect its use may have on individuals”

“You should consider these matters objectively as part of an assessment of the scheme’s impact on people’s privacy. The best way to do this is to conduct a privacy impact assessment. The ICO has produced a ‘Conducting privacy impact assessments code of practice’ that explains how to carry out a proper assessment.”

“If you are using or intend to use an ANPR system, it is important that you undertake a privacy impact assessment to justify its use and show that its introduction is proportionate and necessary.”
“Example: A car park operator is looking at whether to use ANPR to enforce parking restrictions. A privacy impact assessment is undertaken which identifies how ANPR will address the problem, the privacy intrusions and the ways to minimize these intrusions, such as information being automatically deleted when a car that has not contravened the restrictions leaves a car park.”

“Note:
... in conducting a privacy impact assessment and an evaluation of proportionality and necessity, you will be looking at concepts that would also impact upon fairness under the first data protection principle. Private sector organisations should therefore also consider these issues.” “A privacy impact assessment should look at the pressing need that the surveillance system is intended to address and whether its proposed use has a lawful basis and is justified, necessary and proportionate.”

The quotations above taken directly from the ICO’s CCTV Code of Practice state that if Britannia Parking wish to use ANPR cameras then they must undertake a privacy impact assessment to justify its use and show that its introduction is proportionate and necessary. It also states that Britannia Parking must regularly evaluate whether it is necessary and proportionate to continue using it.

Therefore I request that Britannia Parking Ltd provide proof of regular privacy impact assessments in order to comply with the ICO’s CCTV Code of Practice and BPA’s Code of Practice. I also require the outcome of said privacy impact assessments to show that its use has “a lawful basis and is justified, necessary and proportionate”.

The ICO’s CCTV Code of Practice goes on to state:

“5.3 Staying in Control

Once you have followed the guidance in this code and set up the surveillance system, you need to ensure that it continues to comply with the DPA and the code’s requirements in practice. You should:
• tell people how they can make a subject access request, who it should be sent to and what information needs to be supplied with their request;”

“7.6 Privacy Notices
It is clear that these and similar devices present more difficult challenges in relation to providing individuals with fair processing information, which is a requirement under the first principle of the DPA. For example, it will be difficult to ensure that an individual is fully informed of this information if the surveillance system is airborne, on a person or, in the case of ANPR, not visible at ground level or more prevalent then it may first appear.

One of the main rights that a privacy notice helps deliver is an individual’s right of subject access.”
Britannia Parking has not stated on their signage a Privacy Notice explaining the keeper’s right to a Subject Access Request (SAR). In fact, Britannia Parking has not stated a Privacy Notice or any wording even suggesting the keepers’ right to a SAR on any paperwork, NtK, reminder letter or rejection letter despite there being a Data Protection heading on the back of the NtK. This is a mandatory requirement of the ICO’s CCTV Code of Practice (5.3 and 7.6) which in turn is mandatory within the BPA’s Code of Practice and a serious omission by any data processor using ANPR, such that it makes the use of this registered keeper’s data unlawful.

As such, given the omissions and breaches of the ICO’s CCTV Code of Practice, and in turn the BPA’s Code of Practice that requires full ICO compliance as a matter of law, POPLA will not be able to find that the PCN was properly given.

8. The Signs Fail to Transparently Warn Drivers of what the ANPR Data will be used for

The signs fail to transparently warn drivers of what the ANPR data will be used for which breaches the BPA Code of Practice and the Consumer Protection from Unfair Trading Regulations 2008 due to inherent failure to indicate the 'commercial intent' of the cameras.

Paragraph 21.1 of the BPA Code of Practice advises operators that they may use ANPR camera technology to manage, control and enforce parking in private car parks, as long as they do this in a reasonable, consistent and transparent manner. The Code of Practice requires that car park signs must tell drivers that the operator is using this technology and what it will use the data captured by ANPR cameras for.

Britannia Parking signs do not comply with these requirements because these car park signage failed to accurately explain what the ANPR data would be used for, which is a 'failure to identify its commercial intent', contrary to the BPA CoP and Consumer law.

Britannia Parking main sign states: “Camera Controlled Pay on Arrival”
;
Other signs state: “Car park monitored by ANPR systems”

Specifically missing from this sentence is the vital information that these camera images would be used in order to issue Parking Charge Notices. There is absolutely no suggestion in the sentence above that the cameras are in any way related to Parking Charge Notices. The only reference to Parking Charge Notices on Britannia Parking sign makes no mention of Parking Charge Notices being issued as a result of images captured by the ANPR cameras.

In circumstances where the terms of a notice are not negotiable (as is the case with the car park signage, which is a take-it-or-leave-it contract) and where there is any ambiguity or contradiction in those terms, the rule of contra proferentem shall apply against the party responsible for writing those terms.

This is confirmed within the Consumer Rights Act 2015 including: Paragraph 68: 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.

and Paragraph 69:

Contract terms that may have different meanings:

(1) If a term in a consumer contract, or a consumer notice, could have different meanings, the meaning that is most favourable to the consumer is to prevail.

Withholding material information from a consumer about the commercial (not security) purpose of the cameras would be considered an unfair term under The Consumer Protection from Unfair Trading Regulations 2008 because the operator 'fails to identify its commercial intent':

hxxp://www.legislation.gov.uk/uksi/2008/1277/contents/made

Misleading omissions: 6. - (1) ''A commercial practice is a misleading omission if, in its factual context, taking account of the matters in paragraph (2):

(a) the commercial practice omits material information,
(b) the commercial practice hides material information,
(c) the commercial practice provides material information in a manner which is unclear, unintelligible, ambiguous or untimely, or
(d) the commercial practice fails to identify its commercial intent, unless this is already apparent from the context, and as a result it causes or is likely to cause the average consumer to take a transactional decision he would not have taken otherwise.''

It is far from 'apparent' that a camera icon means a car's data is being harvested for commercial purposes of charging in a car park. A camera icon suggests CCTV is in operation for security within the car park.

Therefore, it is respectfully requested that this parking charge notice appeal be allowed and the appeal should be upheld on every point.

Yours faithfully,

Nonconform

Should i take out point 5?

Coupon-mad

Yes I would. As it isn't a winning point and contradicts your point about the being only seen at the exit.

In your first point I would get rid of ANY suggestion that the car 'entered via the exit'!

Note the lack of visible signage from the driver’s point of view when entering the car park this way.

Image showing Britannia Parking car park exit from inside the car park:
hxxps://postimg.cc/62W6zp6x

Image showing available manoeuvring space after driving into Britannia Parking car park EXIT:
hxxps://postimg.cc/HJCkctfx

Note the two yellow railings inside the car park on the left beyond the gate, match the two railings depicted on the NtK ANPR images showing where the car is in relation to the exit.

If the driver of a car which has entered the car park from this EXIT for whatever reason

Nonconform

Agreed on point 5; I will remove the mention of entering via the exit. Thank you Coupon-mad, if everything else is ok, I will convert the doc to pdf format and submit the appeal.

Nonconform

Forgot to ask, are the images I linked ok for the appeal and do I need any of the parking signs, etc to add to the signage section?

Coupon-mad

No idea which images you mean, we are too busy to keep going over older posts we've already answered...