Quote:Good afternoon,

Thank you for your further email.

As mentioned in our previous correspondence, all appeals must be made via our appeals portal https://appeals.ce-service.co.uk/. Our complaints policy clearly states our complaints form is not intended to be used as a method for motorists to appeal a Parking Charge Notice. Our complaints policy does not cover comments regarding the dissatisfaction relating to the issuance of a Parking Charge. Matters relating specifically to appeals must be made in writing as outlined on the back of the Parking Charge Notice.

This ticket was issued within 14 days of the incident date, and we are fully compliant with the requirements of Schedule 4 of the Protection of Freedoms Act 2012. Under POFA 2012, if you fail to provide the full, correct name of the driver and their current address for service you may become liable for the full amount due as the Registered Keeper of the above vehicle.

Yours faithfully, 
Civil Enforcement 
Complaints Team


Civil Enforcement Ltd
Complaints at Civil Enforcement

Email: complaints@ce-service.co.uk

Address: Civil Enforcement Ltd, Horton House,
Exchange Flags, Liverpool L2 3PF.

Quote:Dear Civil Enforcement Ltd,

I write as the registered keeper. Your latest response is noted and will be retained.

Your position is legally and procedurally untenable. You have received a formal complaint. You are required to handle it as a formal complaint. In addition, because that complaint plainly includes a challenge to the validity of the Parking Charge Notice, you are also required to treat it as an appeal.

These are not alternatives. They are cumulative obligations.

Clause 11.2 of the Private Parking Sector Single Code of Practice states:

"Where a parking operator receives a complaint that it considers to be or include an appeal against the validity of a parking charge, the parking operator must also treat it as an appeal for the purposes of applying the timescales in Clause 8.4, and should inform the complainant as such unless and until it is clear that the complaint is not relevant to an appeal or the complainant informs the parking operator that they do not wish it to be so handled."

That wording is clear. A complaint which includes an appeal against the validity of a parking charge remains a complaint, but must also be treated as an appeal. Civil Enforcement Ltd is not entitled to refuse to investigate the complaint, and it is not entitled to refuse to process the appeal.

Your repeated response that "all appeals must be made via our appeals portal" does not answer PPSCoP 11.2. The Code expressly deals with complaints which include appeals. It requires you to treat such complaints as appeals for the relevant timescales. It does not permit you to discard the complaint, ignore the appeal element, and force the keeper back through a defective portal.

Your online portal does not provide any applicable option for a registered keeper appeal based on no keeper liability, PoFA non-compliance, inadequate signage, lack of contract formation, lack of evidence, or failure to specify a period of parking. I will not select a false or misleading option simply to get through your process.

Your statement that the Parking Charge Notice was issued within 14 days is also irrelevant to the specific defect raised. The 14-day requirement is only one element of Schedule 4 of the Protection of Freedoms Act 2012. It does not make the Notice to Keeper fully compliant.

The specific defect is that the Notice to Keeper fails to specify the required "period of parking" under Schedule 4 paragraph 9(2)(a). The "From" and "To" times are merely ANPR entry and exit timestamps. They are not a period of parking.

Your own previous email confirmed that your ANPR cameras record vehicles entering and exiting the car park and are not designed to monitor movements within the car park. That confirms the evidential problem. Entry and exit images do not prove where the vehicle was parked, whether it was parked in breach of any displayed term, what signage was visible, or any actual period of parking.

The alleged breach is "Permit Holders Only". You have provided no evidence of the material signage, no evidence of the terms relied upon, no evidence of the vehicle's parked location, and no evidence that any contractual offer was made to and accepted by the driver. "Permit Holders Only" wording is, on its face, prohibitory rather than contractual.

For the avoidance of doubt, the driver has not been identified and will not be identified. There is no legal obligation to name the driver.

Civil Enforcement Ltd is now formally on notice that its failure to handle this matter correctly will be relied upon in any complaint to the BPA, any complaint concerning DVLA/KADOE compliance, any POPLA appeal, and any future court proceedings.

Civil Enforcement Ltd obtained keeper data from the DVLA for the purpose of pursuing a parking charge in accordance with the applicable rules and Code of Practice. Continuing to process that data while refusing to handle a formal complaint, refusing to apply PPSCoP 11.2, obstructing the appeal route, and continuing enforcement is disputed and will be raised as improper processing and unreasonable conduct.

You must now do all of the following:

1. handle the correspondence as a formal complaint;
   
2. also treat the complaint as an appeal under PPSCoP 11.2;
   
3. either cancel the Parking Charge Notice or issue a formal appeal rejection with a valid POPLA code; and
   
4. cease any escalation, debt recovery referral, or further enforcement activity while the complaint and appeal remain unresolved.
   

There is no legitimate third option in which Civil Enforcement Ltd ignores the complaint, refuses to process the appeal, disregards PPSCoP 11.2, and continues enforcement as if none of this correspondence exists.

Yours faithfully,

[Registered keeper's name]

Quote:Good Morning

We have reviewed the details of your complaint. However, after careful evaluation your correspondence has been identified as an appeal in accordance with our complaints policy that can be found on our website https://www.ce-service.co.uk/complaints-policy/ .
Our complaints policy clearly states our complaints form is not intended to be used as a method for motorists to appeal a Parking Charge Notice. Our complaints policy does not cover comments regarding the dissatisfaction relating to the issuance of a Parking Charge. Matters relating specifically to appeals must be made in writing as outlined on the back of the Parking Charge Notice.
We have passed this onto our appeals team. Please note that our appeals team aims to respond to appeals within 14 days of receipt. However, under the new BPA guidelines, operators are allowed up to 28 days to provide a response.

Kind Regards
Civil Enforcement

Quote:Thank you.

I note that Civil Enforcement Ltd has now confirmed that my correspondence has been identified as an appeal and has been passed to the appeals team.

For the avoidance of doubt, the correspondence remains a formal complaint and must also be handled as such. The appeal element must be dealt with in accordance with PPSCoP 11.2 and the applicable appeal timescales.

Enforcement activity must remain paused while the appeal is under consideration. If the appeal is rejected, a valid POPLA code must be issued.

Yours faithfully,

[Name]

Quote:23/07/26

Vehicle Registration XXXXXX
PCN Reference XXXXXX
Date of Incident 01 May 2026
Site Details SPRING HALL MEDICAL PRACTICE, 173 SPRING HALL LANE, HALIFAX, WEST YORKSHIRE, HALIFAX, HX1 4JG

RESPONSE FROM REPRESENTATIONS TEAM

We refer to your recent correspondence.

It is the drivers responsibility to pay this PCN.

However, in England and Wales, if after 28 days from the Issue Date, this PCN has not been paid or you have not provided
us with the name and current address for service of the driver, then under Section 4 of the Protection of Freedoms Act 2012
we do now have the right, subject to the requirements of the Act having been complied with, to recover from the Registered
Keeper at the time the vehicle was parked, sums that remain unpaid.

Alternatively, you can of course make a payment directly to us and recover the amount due from the driver.
To consider your appeal properly, please provide evidence/documentation that you were a legitimate user of the premises in
question on the date of the parking event. This information should be provided within 14 days, beginning with the date on
this letter, using the online appeal service at https://appeals.ce-service.co.uk.

Yours faithfully,

Quote:Dear Civil Enforcement Ltd,

I write as the registered keeper.

I refer to:

1. your letter dated 10 July 2026 headed “ACTION NEEDED”, now demanding £140 and threatening escalation to £170 plus costs; and
   
2. your representations letter dated 23 July 2026.
   

Your handling of this matter is now plainly unreasonable and procedurally non-compliant.

You have received a formal complaint. That complaint expressly challenges the validity of the Parking Charge Notice. Civil Enforcement Ltd is therefore required to handle it as a complaint and must also treat it as an appeal.

Clause 11.2 of the Private Parking Sector Single Code of Practice states:

“Where a parking operator receives a complaint that it considers to be or include an appeal against the validity of a parking charge, the parking operator must also treat it as an appeal for the purposes of applying the timescales in Clause 8.4, and should inform the complainant as such unless and until it is clear that the complaint is not relevant to an appeal or the complainant informs the parking operator that they do not wish it to be so handled.”

This is not complicated. It is not optional. The complaint remains a complaint. Because it also challenges the validity of the PCN, it must also be treated as an appeal. These obligations are cumulative.

Despite this, Civil Enforcement Ltd has issued a debt escalation letter dated 10 July 2026 demanding £140 and threatening escalation to £170 plus costs. That was sent while the complaint/appeal remained unresolved, before any appeal rejection, and without any POPLA code. That conduct is improper and will be relied upon in complaints to the BPA and DVLA concerning breach of the PPSCoP and misuse of DVLA keeper data under the KADOE regime.

Your letter of 23 July 2026 is no better. It states:

“However, in England and Wales, if after 28 days from the Issue Date, this PCN has not been paid or you have not provided us with the name and current address for service of the driver, then under Section 4 of the Protection of Freedoms Act 2012 we do now have the right, subject to the requirements of the Act having been complied with, to recover from the Registered Keeper…”

That paragraph is a template assertion, not a response to the appeal.

First, there is no automatic right to recover a parking charge from a registered keeper merely because 28 days have passed or because the keeper has not named the driver. Keeper liability under the Protection of Freedoms Act 2012 is strictly conditional.

Second, the relevant provision is Schedule 4, not “Section 4”. If Civil Enforcement Ltd wishes to rely on statutory keeper liability, it should at least be capable of identifying the statute correctly.

Third, your own wording admits the central point: any right to recover from the keeper is “subject to the requirements of the Act having been complied with”. Those requirements have not been complied with.

The Notice to Keeper fails to specify the required “period of parking” under Schedule 4 paragraph 9(2)(a). The “From” and “To” times are merely ANPR entry and exit timestamps. They are not a period of parking.

Civil Enforcement Ltd has already stated that its ANPR cameras record vehicles entering and exiting the car park and are not designed to monitor movements within the car park. That confirms the evidential defect. Entry and exit images do not prove where the vehicle was parked, whether it was parked in breach of any displayed term, what signage was visible, or any actual period of parking.

Your request for evidence that I was “a legitimate user of the premises” is also misconceived. I am appealing as the registered keeper. The driver has not been identified and will not be identified. There is no legal obligation to identify the driver and no obligation on the keeper to prove that they personally were a legitimate user of the premises.

Civil Enforcement Ltd is now formally on notice that the following will be relied upon in any BPA complaint, DVLA/KADOE complaint, POPLA appeal, and any future court proceedings:

• the defective online appeal portal;
  
• the formal complaint and appeal correspondence;
  
• your refusal to apply PPSCoP clause 11.2 properly;
  
• your 10 July 2026 debt escalation letter;
  
• your unsupported assertion of keeper liability;
  
• your failure to provide a POPLA code; and
  
• your continued processing of keeper data for enforcement while the complaint and appeal remain unresolved.
  

You must now do all of the following:

1. confirm that the formal complaint remains live and is being investigated as a complaint;
   
2. confirm that the same correspondence is also being treated as an appeal under PPSCoP clause 11.2;
   
3. cancel the Parking Charge Notice or issue a formal appeal rejection with a valid POPLA code;
   
4. withdraw the £140 escalation and confirm that no debt recovery or legal escalation will occur while the appeal and complaint remain unresolved.
   

There is no legitimate position in which Civil Enforcement Ltd can receive a complaint that includes an appeal, refuse to deal with it properly, escalate the charge, threaten debt recovery, withhold POPLA access, and still pretend to be acting in accordance with the PPSCoP or the conditions attached to DVLA keeper data access.

Yours faithfully,

[Registered keeper’s name]

Quote:Subject: PCN [PCN number] – failure to provide POPLA code/complaint and appeal remain live

Dear Civil Enforcement Ltd,

I write as the registered keeper.

I refer to your letter dated 10 August 2026.

Your position is incoherent.

Civil Enforcement Ltd previously confirmed that my correspondence had been identified as an appeal and had been passed to your appeals team. You cannot now assert that it is "too late" to appeal.

For the avoidance of doubt, the formal complaint remains live. Under PPSCoP clause 11.2, because that complaint includes a challenge to the validity of the Parking Charge Notice, Civil Enforcement Ltd must handle it as a complaint and must also treat it as an appeal. Those obligations are cumulative.

If your letter dated 10 August 2026 is intended to be an appeal rejection, you must issue a valid POPLA code.

If it is not an appeal rejection, then the appeal remains live and you must either cancel the Parking Charge Notice or issue a proper appeal rejection with a valid POPLA code.

Your repeated generic reference to the Protection of Freedoms Act 2012 does not answer the appeal. Keeper liability is not created merely because 28 days have passed or because the keeper has not named the driver. It is conditional upon full compliance with Schedule 4. The Notice to Keeper fails to specify the required period of parking under Schedule 4 paragraph 9(2)(a). ANPR entry and exit timestamps are not a period of parking.

Your continued demands for payment, including the threat of escalation, while refusing to process the complaint and appeal properly and withholding POPLA access, will be relied upon in complaints to the BPA and DVLA concerning breach of the PPSCoP and improper use of DVLA keeper data.

You must now confirm, within 7 days, either:

1. the Parking Charge Notice is cancelled; or
   
2. the appeal is rejected and a valid POPLA code is provided.
   

No further payment demands, debt escalation or third-party referral should occur while the complaint and appeal remain unresolved.

Yours faithfully,

[Registered Keeper's name]