Horizon parking (Double dip)

[b789]

Typical fob-off by Horizon. @Foxy01, I think it is worth responding because Horizon’s explanation still leaves a major unanswered question.

They say the cameras "missed" both the morning exit and the later re-entry, but that could mean either no images were captured at all, or images were captured but not correctly read/matched to the VRM. Those are very different failures.

If no images whatsoever exist, Horizon is saying the same vehicle was completely missed twice on the same day, despite being successfully captured immediately before and after those movements. That needs explaining. If images do exist but were misread, rejected or orphaned, they are still personal data and should be disclosed under a SAR.

The response therefore forces Horizon to clarify exactly what happened and requests all underlying ANPR images/data rather than simply accepting their assertion that the two movements were "missed".

Dear Mr Middleton,

Thank you for your response.

Your explanation confirms that the Parking Charge was issued because Horizon's ANPR record showed only two events: an entry at 09:03 and an exit at 18:28. You now accept, on the evidence provided, that the vehicle actually left the site after the morning visit and returned again later that afternoon.

However, your explanation raises a more important technical issue which has not been addressed.

You state:

"it appears that the cameras have missed your exit from the car park in the morning and subsequent entry in the afternoon."

There is a critical distinction between:

  1. the cameras producing no images whatsoever of those two intervening movements; and

  2. images having been captured, but the ANPR/OCR system failing to read, correctly identify, match or associate those images with the vehicle's correct registration.

Those are entirely different failure modes.

An OCR or recognition failure means that an image may still exist, even though it was not associated with the correct VRM. A complete capture failure means that the vehicle passed through the camera-controlled entry or exit point and no usable image of that movement was generated at all.

Your response appears to assert the latter: that the vehicle was successfully captured entering at 09:03; was then completely missed when it left; was completely missed again when it returned later that day; and was then successfully captured leaving at 18:28.

That is a striking sequence and requires considerably more explanation than the statement that errors can occasionally occur.

The probability of two complete photographic capture failures for the same vehicle depends upon Horizon's actual physical capture rate, which you have not disclosed.

By illustration only, if the cameras successfully captured an image on 99.5% of vehicle movements, the probability of completely failing to capture both of two specified movements, assuming independent failures, would be:

0.5% × 0.5% = 0.0025%

or approximately 1 in 40,000.

If the physical capture rate were 99.9%, the probability would be:

0.1% × 0.1% = 0.0001%

or approximately 1 in 1,000,000.

I do not suggest that either figure represents Horizon's actual performance. That is precisely the point. Horizon has described these incidents as occurring in a "very small number of instances" while declining to provide the data necessary to establish what "very small" actually means.

Your further statement that there were no "partial reads, rejected reads and unmatched vehicle images for your vehicle" does not resolve the issue.

If an image was captured but the OCR system read the registration incorrectly, assigned a different VRM, failed to generate a VRM, or placed the event into an unmatched, rejected or exception dataset, that image would not necessarily appear in a search conducted against the correct registration number.

Accordingly, please answer the following precise question:

Has Horizon's technical investigation positively established that no image whatsoever was captured on either of the two intervening movements, or has Horizon merely established that no correctly recognised and matched ANPR record for those movements exists against the vehicle's correct registration?

Those propositions are fundamentally different.

If Horizon has established that no image whatsoever was captured on either occasion, please confirm:

   1. what records or underlying camera data were examined by the technical team to reach that conclusion;

   2. whether raw camera records were examined rather than simply conducting a search against the correct VRM;

   3. whether any camera fault, obstruction, lane issue, lighting condition, tailgating event or other technical or environmental cause was identified;

   4. whether both failures occurred on the same camera or lane; and

   5. what corrective action was taken following the technical investigation.

If, however, Horizon merely found no correctly matched ANPR event against the correct VRM, that does not establish that the underlying images do not exist.

You also state:

"For every Parking Charge, we review the events of the vehicle to ensure we have each entry and exit."

In this case Horizon demonstrably did not have each entry and exit.

If no intervening images existed at all, I accept that the individual member of staff reviewing the available images could not reasonably have been expected to identify images which did not exist. That would, however, expose a different weakness in Horizon's quality-control process.

Two isolated ANPR captures establish only that the vehicle was present at two particular moments. They do not, without further evidence, establish continuous presence throughout the entire period between those captures.

A manual review which merely confirms that there is a first entry image and a later exit image cannot establish that the ANPR record is complete.

This is particularly significant because the Private Parking Sector Single Code of Practice expressly recognises the problem of "double dipping", where cameras fail to record every entry and exit, and requires manual quality control to guard against such errors.

The issue is therefore no longer simply whether somebody looked at the photographs before issuing the Parking Charge. It is whether Horizon's review process is actually capable of identifying an incomplete ANPR sequence before a financial demand is sent to a motorist.

In this case it plainly did not do so.

SUBJECT ACCESS REQUEST

For the avoidance of doubt, this section constitutes a formal Subject Access Request pursuant to Article 15 UK GDPR.

I require a copy of all personal data held by Horizon Parking relating to me and/or vehicle registration [VRM] arising from the vehicle's presence at [site] on [date].

This request includes, but is not limited to:

   1. Every ANPR image depicting the vehicle on that date, including overview images and number-plate or plate-patch images.

   2. Any image depicting the vehicle regardless of what VRM, if any, Horizon's ANPR/OCR system assigned to that image.

   3. Any image of the vehicle where the registration was unread, partially read, incorrectly interpreted, rejected, manually amended or associated with another registration.

   4. Any unmatched, unpaired, orphaned, rejected or exception ANPR event which depicts the vehicle.

   5. All ANPR event records associated with the vehicle, including timestamps, camera identifiers, lane identifiers, entry/exit classifications and machine-generated VRM data.

   6. Any OCR confidence score, read-confidence data, exception flag, rejection code or other machine-generated metadata associated with any image or event depicting the vehicle.

   7. The complete audit trail relating to the generation and manual review of this Parking Charge, including the date and time of review and any record showing what information and images were available to the reviewer.

   8. All records, notes, findings and communications produced or considered during the technical investigation referred to in your response, insofar as they contain my personal data or data relating to the vehicle and its ANPR events.

   9. All internal notes, appeal records, complaint records and cancellation records containing my personal data or relating to the processing of the vehicle's ANPR data.

The search must not be restricted merely to records indexed under the correct VRM.

The very issue under investigation is whether an image of the vehicle may have been captured but incorrectly recognised, rejected, unmatched or associated with another registration.

The vehicle is:

   [make/model/colour]

The two known images already held by Horizon at 09:03 and 18:28 provide an unambiguous visual reference from which the vehicle can be identified.

The approximate intervening movements were:

   Morning exit: [approximate time]

   Afternoon re-entry: [approximate time]

Those time windows should permit a focused and proportionate search of the relevant camera and ANPR records.

Please also preserve all relevant raw images, event records, associated metadata, audit information and technical-investigation records pending completion of this Subject Access Request and complaint.

Finally, you have stated that this type of occurrence happens only in "a very small number of instances".

You are of course entitled to decline voluntary disclosure of commercially held aggregate statistics. However, that does not answer the separate question of what objective evidence supports Horizon's assertion about the frequency of such failures.

Please therefore confirm:

   1. whether Horizon records the number of ANPR-generated Parking Charges subsequently cancelled because one or more entry or exit events were missed;

   2. whether Horizon records cancellations caused by incorrect, rejected or unmatched ANPR reads;

   3. whether Horizon has calculated the proportion of its ANPR-generated Parking Charges affected by such failures;

   4. whether those records are examined as part of BPA compliance auditing; and

   5. whether your statement that these incidents occur only in "a very small number of instances" is based upon measured data rather than assumption.

Cancellation of the individual Parking Charge does not resolve this complaint.

The complaint concerns the reliability of Horizon's ANPR evidence, the effectiveness of its pre-issue checking process, the precise nature of the two unexplained missing movements, and the evidential basis upon which Horizon describes these failures as exceptionally uncommon.

Please treat this as a continuation of the formal complaint and separately as a Subject Access Request.

If Horizon considers its internal complaints process exhausted, please confirm that this is your final complaint response so that the matter can be referred to the British Parking Association and raised with my Member of Parliament.

Yours sincerely,

[Name]

Put them on the spot. I still advise that the recipient of the PCN (the Keeper) raise this with their MP. Unless this kind of pressure is put on these scammers, nothing will change.