No appeal without saying whether the keeper drove or not - please advise

Chr1sC

Hi all,

Posting on behalf of the registered keeper. Have read the NEWBIES thread which (having contacted the landowner and been directed back to azure multiple times) suggests the keeper should appeal via the relevant website but not mention who the driver was and if they (keeper) were driving. On the website, it won't let them appeal without saying yes or no to whether they were driving though. Not sure how to proceed, would appreciate guidance.

The Basics:

Parking Company: Azure Parking Ltd

Location: St Peter's, Northampton, NN1 1PS

Date of Contravention: 02/12/2025 at 11:55

Date of NTK (Notice to Keeper): 05/12/2025

Amount: £100 (reduced to £60 if paid within 14 days - this window has now passed)

What Happened:

According to Azure's records:

Entry: 09:32

Exit: 11:55

Duration: 2 hours 23 minutes

Free period: 2 hours

Evidence Provided by Azure:

The website shows 4 photos:

ANPR capture of registration plate (entry)

ANPR capture of registration plate (exit)

Wide shot of car park showing vehicle entering

Wide shot of car park showing vehicle exiting

NO photo of the vehicle actually parked. Only entry/exit ANPR images.

No appeal submitted yet - Nothing has been sent to Azure. The keeper has not engaged at all so far. 

I have attached the letter and screenshots from the website.

For broader consideration, the keeper has quite a bit of debt which is currently unpaid and are in the process of arranging a £1 per month payment plan so there is no possibility of them paying the amounts invoiced for by azure.

Coupon-mad

Use their complaints policy instead, and contact them to complain about their website making appeal conditional on saying whether the keeper was driving. Tell them you will report them to the BPA for this scammery AND they must also treat this complaint as an appeal from the keeper who requires a POPLA Code.

This rogue conduct is not allowed and was outlawed by the DVLA over ten years ago.

This was discussed a month ago:

https://forums.moneysavingexpert.com/discussion/6643173/azure-appeals-page#latest

I think 'PayMyParkingCharge'  is ZZPS' rogue webpage. You should also complain to the BPA about ZZPS.

doubledotcom

Or you can send the appeal as an email to their DPO with a rider at the beginning which forces the DPO to acknowledge receipt of the appeal. You are right to treat that “driver declaration” as a trap. A keeper can lawfully refuse to identify the driver, and an operator cannot make a valid appeal route conditional on you surrendering that position.

If the operator offers no workable appeal channel (because the webform forces an admission/denial you are not obliged to make), sending the appeal by email to the operator’s DPO (or privacy inbox) with a clear “service” rider creates an audit trail: (1) you have appealed within time, (2) you have raised a UK GDPR issue, and (3) you have put them on notice that their process is defective.

Just send the appeal email to the DPO with the following rider at the beginning:

This email is a formal data protection complaint and Article 12 UK GDPR request for action. Your appeals webform compels a keeper to state whether they were the driver, despite no legal duty to identify the driver, thereby forcing unnecessary personal data. The Data Protection Officer must ensure this is investigated and responded to under Article 12(3) within one month. As no alternative appeal route is offered, this email must also be logged as served on the operator today.

The appeal set out below is therefore deemed served on the operator as of today’s date and must be forwarded without delay to the appropriate department for consideration and action.

Then just append the appeal wording.

Chr1sC

Thanks very much for the advice so far, this has been extremely helpful.

We emailed the GDPR email address (dataprotection@zzps.co.uk) on 01/01/2026 as follows:

This email is a formal data protection complaint and Article 12 UK GDPR request for action. Your appeals webform compels a keeper to state whether they were the driver, despite no legal duty to identify the driver, thereby forcing unnecessary personal data. The Data Protection Officer must ensure this is investigated and responded to under Article 12(3) within one month. As no alternative appeal route is offered, this email must also be logged as served on the operator today.

The appeal set out below is therefore deemed served on the operator as of today’s date and must be forwarded without delay to the appropriate department for consideration and action.

Re PCN number: ********

I dispute your 'parking charge', as the keeper of the vehicle. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner and the BPA.

There will be no admissions as to who was driving and no assumptions can be drawn. Since your PCN is a vague template, I require an explanation of the allegation and your evidence. You must include a close up actual photograph of the sign you contend was at the location on the material date as well as your images of the vehicle parked within the area to which the parking restrictions apply.

If your allegations concern a PDT machine, the data supplied in response to this appeal must include the record of payments made - showing partial VRNs - and an explanation of the reason for the PCN, because your Notice does not explain it.

If the allegation involves an alleged overstay of minutes, your evidence must include the actual grace period agreed by the landowner.

There was an auto-response which said:

Thank you for contacting the Data Protection Department.

This is an automated reply to confirm your message has been received and is currently under review; if your request meets the requirements set out within the GDPR you should expect to receive a response from us within one calendar month.

If you have sent us an email with an appeal for your Parking Charge or Penalty Notice, please note that we do not process appeals and your email will not count as a formal appeal against your charge. If you wish to formally dispute your Parking Charge or Penalty Notice, then please send your email to appeals@paymyparkingcharge.com. Failure to follow our internal appeals process correctly may hinder your ability to submit an independent appeal.

If we require any further information to complete your request, i.e. we are unsure of your identity, we will contact you to request this. Once received and we have verified your identity, the one calendar month timeframe will begin. Please note, a request for proof of identity may be required to ensure we do not disclose any personal information that would result in a data breach, it is not requested to cause a delay in our response.

If you would like information as to how we collect, use, maintain and disclose your data, please visit our website
www.zzps.co.uk
where you will find our Privacy Policy.

Many thanks and kind regards,

We then sent the same email also on 01/01/2026 to: appeals@paymyparkingcharge.com

We received this autoresponse:

We thank you for your email and can confirm its receipt.

You can manage your parking charge or penalty notice via our website at www.paymyparkingcharge.com where you can view photographic evidence and make payments by credit or debit card.

Should you need to speak to someone regarding your email please telephone our offices on 01932 918098 during opening hours - Monday to Friday 08:30 - 17:30 (excluding bank holidays).

We will endeavour to respond as quickly as possible however please do not resend your message as this will delay our response so please wait to hear from us.

Please note that we are currently receiving a high volume of correspondence.  Whilst we are making every effort to respond to all emails in a timely manner, this process will be greatly assisted by you refraining from sending follow-up emails before you have received our response.

The receipt of this auto response means that we have received your email and will answer it as soon as possible.

Please be assured, you will not be asked to pay a charge at a higher rate due to any delay on our part, and will always be given the opportunity to settle it at the rate it was at on receipt of your email.

This is an automated response - please do not reply to this message.

On 05/01/2026 we received this reponse to the data protection email (including as screenshot as signature is a picture and not copyable as text):



On 10/01/2026, we received this letter:



I have not currently complained to the BPA.

Any advice on the best next steps would be greatly appreciated.

Thanks very much

kryten3000

Did you forward the email to appeals@ as suggested by their response?

Personally I would state "not the driver" if forced to make a declaration on one of these appeal pages - at this point in the process the keeper is not under oath.

ChirpyChicken

You can email any zzps pcn via email so job done
Customer.services@zzps.co.uk

Coupon-mad

If you have emailed the appeal just wait.

Chr1sC

We emailed the same appeal information that we sent to the data protection email to the appeals@paymyparkingcharge.com email address (the one from the auto response for the data protection mailbox).

Happy to now wait.

If I understand correctly, despite having received this debt chaser, we are actually waiting for something that acknowledges the appeal and provides a code with which to challenge the rejection of the appeal (assuming it is rejected, of course), is that correct?

If nothing arrives acknowledging the appeal, is there a length of time or a stage of other communications received at which a further course of action is suggested?  I don't need to know details, I'm just wondering so that I can put the recipient's mind at ease by setting clear expectations about the steps and the process to manage the worry that the letters can create.

Thanks again for your ongoing support

Coupon-mad

I'd email ZZPS as suggested by @ChirpyChicken and say you have already appealed as registered keeper so their chaser letter is pure intimidation. Wind your necks in and reply to the appeal with a POPLA code or ZZPS will be reported to the BPA.

Chr1sC

Latest update summary of new events:

1. On 14th January, the registered keeper responded to the "debt resolution" letter received on 10th January (dated 6th January) by sending an email to customerservices@zzps.co.uk as suggested to ask them to stop with intimidation and requesting a POPLA code.

2. On 21st January the registered keeper received a response to the email sent 1st January (appeals@paymyparkingcharge.com) stating there is sufficient signage and giving 14 days to respond to outline the reasons for the appeal.

3. On 27th January the registered keeper received an email response to the same email which had been sent to the zzps data protection email address also on 1st January. This included a dropbox link and separately they sent the password. This was not accessed within 30 days and so we cannot see what this file contained as the link only works for 30 days.

4. On 5th March the registered keeper received another letter almost identical to the 10th January debt recovery letter above, this time dated 25th February, demanding payment.

Please note, the keeper is a vulnerable individual, please keep any advice focussed on what can be done now, not what should have been done earlier.

Details of the new correspondence is included below:
1:

I have already appealed as registered keeper, please stop these intimidating letters and provide a POPLA code. PCN 24318596

2:

Parking charge - 24318596

Good morning,
Thank you for your email.
Please note, this site offers a two(2) hour free parking session from the arrival to the site and your vehicle remained on site for two(2) hours and twenty-three(23) minutes. There is sufficient signage on site to notify motorists of the terms and conditions on site and there is also signage on the entrance to the site. It is the motorist’s responsibility to ensure that they always adhere to this signage.

Please respond to this email within fourteen(14) days outlining your reason of appeal. OR submit the drivers full name and address to have this transferred and give them the chance to appeal.

Alternatively, please make a payment of £100 within fourteen(14) days to settle this charge.

If neither of these options are done within fourteen(14) days, the case will continue to progress and further charges may be applied.

Kind regards

Luke

3:

Our References: 154924450

Further to your request under UK GDPR we have made the requested information available via the below Dropbox link*:

https://www.dropbox.com…

This link has been password protected for security; we will be sending a separate email shortly which will contain the password required to access the link. 

If you experience any difficulty in accessing the information, please contact us either via telephone on +4419 3291 8916 or alternatively by replying to this email so that we may assist you. 

*Please note for security this link will expire after thirty (30) calendar days from the date when all documents are available to you, and so, the information contained therein will no longer be accessible.

Yours sincerely
Data Protection Department

4:

I am considering advising the keeper to respond that the appeal was already made on 1st January 2026 within time and reiterating that ZZPS/Azure must provide a POPLA code if they choose to reject. If taking this approach, I would propose to reiterate that the keeper contends that no contract is formed and no evidence of signage or a breach has been provided.

I am also considering whether it is worth expanding the appeal wording. I have reviewed this thread where user57 seems to have been successful by arguing that no contract was formed, failure to meet BPA code of practice, no evidence of a breach, disproportionate and punitive charges, no keeper liability has been established and no evidence of land owner authority has been provided.

It seems like referring to the transfer of liability to the registered keeper depending on compliance with Schedule 4 of the Protection of Freedoms Act 2012 has had the effect of encouraging ZZPS to withdraw the charge once a POPLA appeal has been made which is an outcome I would love to replicate, so I think it might be good to reference this.

I have reviewed to assess the similarities to this case. The similarities to this case seem to be: no signage on entry to car park, no evidence provided of signs or of the actually car parked (accepting there are photos of the car entering and exiting), a handling fee has been added on the website of £1.95 which is not included on the letters, no evidence of landowner authority, no evidence of who the driver is.

Primarily I would like to request advice on the best course of action to take next. Any advice on the relevance of the case I have mentioned and their successful appeal approach to this one would be appreciated.

Any further details required, please let me know.

Thanks very much in advance for your ongoing support.

Coupon-mad

Please note, the keeper is a vulnerable individual, please keep any advice focussed on what can be done now, not what should have been done earlier.

Nothing was done wrong by you.

ZZPS are rogues IMHO, based on their replies to motorists. Especially the way they block appeals and expect people to use a time-limited password to see replies that could & should just be emailed or posted.

I'd get the keeper's constituency MP on the case. MPs often deal with complaints about parking firms and their cling-on DRAs.

Ask the MP to complain to the BPA.