Quote:I appeal as the registered keeper. I am not obliged to identify the driver and I will not be doing so.

Liability is denied.

The Notice to Keeper does not comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012. In particular, it fails to specify any “period of parking” as required by paragraph 9(2)(a). The notice merely gives “From” and “To” times which appear to be ANPR entry and exit timestamps. Time on site is not the same as a period of parking, and ANPR images of a vehicle entering and leaving do not prove when, where, or for how long the vehicle was parked.

The alleged contravention is stated as “Permit Holders Only”, yet the evidence supplied consists only of entry and exit images. This does not prove that the vehicle was parked in breach of any displayed term, nor does it show the location of any alleged parking, the signs in place, the terms relied upon, or that any contract was offered to and accepted by the driver.

Further, wording such as “Permit Holders Only” is, on its face, prohibitory. Civil Enforcement must prove that the signage at the material location was capable of creating a contractual offer to a non-permit holder, rather than merely forbidding parking by unauthorised vehicles.

For the avoidance of doubt, I require Civil Enforcement to cancel this Parking Charge Notice. If you reject this appeal, you must issue a POPLA code so that the matter can be referred to independent appeal.

Quote:Subject: Formal complaint and registered keeper appeal – PCN [insert PCN number]

Dear Civil Enforcement Ltd,

I write as the registered keeper.

This is both a formal complaint and a registered keeper appeal against the above Parking Charge Notice.

I attempted to use your online appeal portal. However, your mandatory drop-down menu does not provide any applicable option for a registered keeper appeal disputing keeper liability, PoFA compliance, signage, contract formation, lack of evidence, or failure to specify a period of parking. The available options appear to be designed around driver-based admissions or irrelevant factual excuses. I will not select an inaccurate option or make any statement that may misrepresent my position.

As this complaint directly concerns the issue, validity and enforceability of the Parking Charge Notice, you are required to treat it as an appeal in accordance with the Private Parking Single Code of Practice section 11.2.

Liability is denied. I am not obliged to identify the driver and I will not be doing so.

The Notice to Keeper does not comply with Schedule 4 of the Protection of Freedoms Act 2012. In particular, it fails to specify the “period of parking” required by paragraph 9(2)(a). The notice merely gives “From” and “To” times which appear to be ANPR entry and exit timestamps. Time on site is not the same as a period of parking. ANPR images of a vehicle entering and leaving do not prove when, where, or for how long the vehicle was parked.

The alleged contravention is stated as “Permit Holders Only”. However, the evidence shown on the notice consists only of entry and exit images. That does not prove that the vehicle was parked in breach of any displayed term. It does not show the location of any alleged parking, the signs in place, the visibility of those signs, the terms relied upon, or that any contractual offer was made to and accepted by the driver.

Further, “Permit Holders Only” wording is, on its face, prohibitory. You are put to strict proof that the signage at the material location was capable of creating a contractual offer to a non-permit holder, rather than merely forbidding parking by unauthorised vehicles.

You are also required to explain why your online appeal process does not provide a suitable option for a registered keeper appeal based on PoFA, signage, contract formation or no keeper liability, and why a keeper should be forced to select an inaccurate or irrelevant option in order to access the appeal process.

For the avoidance of doubt, I require you to cancel this Parking Charge Notice.

If you reject this appeal, you must issue a POPLA code.

Yours faithfully,

[Registered keeper’s name]

1. the keeper submitted an appeal;
   
2. CE wrongly diverted it into "complaints" despite accepting it was an appeal;
   
3. their online appeal portal provides no proper keeper appeal option;
   
4. CE must either cancel or issue a POPLA code.
   

Quote:Dear Civil Enforcement Ltd,

I write further to your response.

For the avoidance of doubt, my previous correspondence was a registered keeper appeal and formal complaint. You have expressly identified it as an appeal. You must therefore process it as an appeal, or forward it internally to the correct appeals department. It is not acceptable to refuse to process a valid keeper appeal simply because your online portal does not provide any applicable appeal reason.

Your online appeal system requires the keeper to select from a restrictive list of reasons, none of which applies. There is no suitable option for a registered keeper appeal based on no keeper liability, failure to comply with Schedule 4 of the Protection of Freedoms Act 2012, 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 in order to access the appeal process.

Your response also confirms that you use ANPR cameras which record vehicles entering and exiting the car park and are "not designed to monitor movements within the car park". That confirms my appeal point. Entry and exit images do not prove any period of parking, do not prove where the vehicle was parked, do not prove that the vehicle was parked in breach of any term, and do not prove that any relevant signs or terms were visible to the driver.

The Notice to Keeper fails to specify the period of parking as required by Schedule 4 paragraph 9(2)(a) of the Protection of Freedoms Act 2012. The "From" and "To" times are merely ANPR entry and exit timestamps. They are not a period of parking.

Liability remains denied. I am not obliged to identify the driver and I will not be doing so.

You are required to cancel the Parking Charge Notice or issue a POPLA code. If you refuse to process this appeal or fail to issue a POPLA code, I will rely on this correspondence in a complaint to the BPA and in any subsequent POPLA appeal or litigation, should it come to that.

Yours faithfully,

[Registered keeper’s name]

Quote:PCN [insert PCN number] – formal data complaint, ignored keeper appeal, and notice of reliance

Dear Civil Enforcement Ltd,

I write as the registered keeper.

This email is sent to your Data Protection Officer because Civil Enforcement Ltd has obtained, processed and continues to process my personal data obtained via the DVLA in connection with the above Parking Charge Notice. This is also a formal complaint and registered keeper appeal.

For the avoidance of doubt, liability is denied. The driver has not been identified and will not be identified.

Civil Enforcement Ltd has already been put on notice that the online appeal portal does not provide any applicable appeal option for a registered keeper appeal based on keeper liability, PoFA compliance, signage, contract formation, lack of evidence, or failure to specify a period of parking. I will not select a false or misleading appeal reason simply to satisfy your defective online process.

Despite this, I have now received a reminder notice dated 12 June 2026 demanding payment and warning of further enforcement action. That reminder has been issued while my appeal remains unanswered. No appeal rejection has been issued. No POPLA code has been provided. No substantive response has been given to the PoFA, signage, contract formation or evidential points already raised.

In your previous email sent by your Complaints Team, you stated that Civil Enforcement Ltd uses ANPR cameras which record vehicles entering and exiting the car park and that those cameras are not designed to monitor movements within the car park. That statement is directly relevant. Entry and exit timestamps do not prove any actual period of parking, do not prove where the vehicle was parked, do not prove whether the vehicle was parked in breach of any displayed term, and do not prove what signage was visible from any alleged parked position.

The Notice to Keeper fails to specify the required “period of parking” under Schedule 4 paragraph 9(2)(a) of the Protection of Freedoms Act 2012. The “From” and “To” times are merely ANPR entry and exit times. They are not a period of parking.

The alleged breach is stated as “Permit Holders Only”. However, no evidence has been provided showing the material signage, the terms relied upon, the location of the vehicle, or that any contractual offer was made to and accepted by the driver. “Permit Holders Only” wording is, on its face, prohibitory rather than contractual.

Civil Enforcement Ltd is now formally on notice that this email, all previous correspondence, the defective online appeal screen, your previous email from the Complaints Team, and the reminder notice will be relied upon in any complaint to the BPA, any POPLA appeal, and any future court proceedings. If you continue enforcement, pass this matter to any debt recovery agent, or otherwise continue processing my data for enforcement purposes without first dealing properly with the registered keeper appeal and issuing a POPLA code if rejected, that conduct will be relied upon as unreasonable and improper.

If this email has reached the wrong internal department, it must be forwarded immediately to the correct department. Civil Enforcement Ltd cannot avoid responsibility by failing to publish a usable appeal email address while operating an online appeal process that does not permit a proper registered keeper appeal.

You must now do one of the following:

1. cancel the Parking Charge Notice; or
   
2. issue a formal appeal rejection with a valid POPLA code.
   

Please confirm within 7 days that the Parking Charge Notice has been cancelled or provide the POPLA code.

Yours faithfully,

[Registered keeper’s name]