PCN Civil Enforcement Spring Hall Medical Practice, Halifax

[3Sh3roo]

Hi b789,

The registered keeper (not driver) received the following PCN by post, can you please advise best defense? (Edited as date of contravention is 01/05/2026 NOT 08/05)

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This case concerns a Parking Charge Notice (private parking firm) issued by Civil Enforcement Ltd, relating to an alleged contravention on Friday, 01 May 2026. The notice itself is dated an unspecified date, and I first became aware of it via received initial notice.

The notice appears to have been issued as By post (ANPR/camera). Driver identified status: NO. Equality Act considerations: No. The location is stated as Spring Hall Medical Practice, Spring Hall Lane, Halifax.

A preliminary Protection of Freedoms Act (PoFA) assessment indicates PENDING: Enter the notice issue date to calculate deemed delivery and timing. Route applied: Not specified. The notice is treated as given on Not available.

Current stage:
- Notice responded to: No
- Debt recovery letters: No
- Letter of Claim: No
- County Court claim: No

Please can I have advice on the strongest next steps and defence points for this case.

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[b789]

Hi, once again, @3Sh3roo. Your vehicles do seem to have a habit of collecting PCNs. Never mind. We can easily deal with this one.

The first point is that we need to see the actual signage at the site before forming a final view. The allegation on the NtK is simply “Permit Holders Only”, but the only evidence shown on the notice is ANPR-style entry and exit images. Those images only show the vehicle moving into and out of the site. They do not show where the vehicle was parked, whether it was parked at all, what signs were visible from the place where the vehicle stopped, whether any entrance sign was adequate, or whether any contractual terms were properly brought to the driver’s attention.

That is particularly important because “Permit Holders Only” wording can often be prohibitory rather than contractual. If the signs merely say that only permit holders may park, that may not amount to an offer of parking to a non-permit holder. In simple terms, a sign saying “permit holders only” may be saying “you are not allowed to park here” rather than offering a contract to park for £100. That distinction matters.

The NtK also has a PoFA problem. Although it gives “From” and “To” times, those appear to be ANPR entry and exit times. PoFA Schedule 4 paragraph 9(2)(a) requires the notice to specify the “period of parking” to which the notice relates. Time on site is not the same thing as a period of parking. ANPR captures a vehicle passing cameras; it does not prove when, where, or for how long the vehicle was actually parked.

So the immediate position is that Civil Enforcement have alleged a permit-only contravention but have not shown any evidence of parking, any evidence of the alleged parked location, or any evidence of the signs and terms said to have created the alleged contract.

The initial appeal should not identify the driver. The keeper should require Civil Enforcement to prove the signage, the contractual terms, the location of the vehicle, and the alleged period of parking.

As an initial appeal is automatically rejected, it does not have to be detailed. Once rejected, you will receive a POPLA code which will allow for a more comprehensive appeal and require CE to provide more evidence. However, do not pin your hopes on POPLA as it will depend on whether you get a fully trained assessor or the janitor.

For now, just use the following as your initial appeal wording and come back when you receive the rejection:

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.

[3Sh3roo]

Thanks b789, once again really appreciate your help, just tried to appeal on their website and they are giving the following options otherwise I cannot proceed, see attachment, should I pick 'I was not there at the time stated on the Parking Charge'? 

For the record, it was a family member driving it and sadly (for me!) I do have a fair share of them that can't seem to see signs and park properly! 

I think I should just let them pay the fine so they learn the hard way!? 

I'll owe you another coffee, after this one...

[b789]

Do not select any of those options if none of them accurately applies. That appeal menu is plainly designed around driver-based excuses and does not provide any proper option for a registered keeper appeal based on PoFA, signage, contract formation, lack of evidence, or no keeper liability.

You should take a screenshot of that page and keep it. It may be useful later at POPLA because it shows that Civil Enforcement’s online appeal process obstructs a proper keeper appeal and tries to funnel appellants into options that either imply driver identity or concede facts.

You should send it by email as part of a formal complaint. Under the PPSCoP, where a complaint concerns the validity or handling of a parking charge, the operator must treat it as an appeal where appropriate.

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]

Email it to complaints@ce-service.co.uk and CC it to office@ce-service.co.uk and yourself.

Civil Enforcement’s own complaints policy says complaints must be made in writing and that a complaint concerning a parking charge can be processed with the complainant’s full name and valid email address. Their site tries to push appeals through the online appeal portal, but that is precisely the problem here because the portal gives no valid keeper appeal option.

[3Sh3roo]

I got the following response today after sending the above email:

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Good afternoon,

Thank you for completing our online complaints form.  
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.
All appeals must be made in writing to our appeals department. We advise that you submit an appeal using the online appeal service http://appeals.ce-service.co.uk/ as the keeper of the vehicle.
Please note we do not operate CCTV at this location. We use Automatic Number Plate Recognition (ANPR) cameras that record all vehicles entering and exiting the car park. The high-tech cameras are not designed to monitor movements within the car park.

Yours faithfully, 
Civil Enforcement 
Complaints Team
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Can you please advise next steps?

[b789]

@3Sh3roo, Civil Enforcement’s response is useful. They have effectively confirmed that the system only records entry and exit and is "not designed to monitor movements within the car park". That supports the keeper’s point that ANPR timestamps are not evidence of a period of parking, nor of where the vehicle stopped, whether it was parked, or what signs were visible.

The next step is to reply once, immediately, in the same email chain. Keep it short. The point is to create the paper trail that:

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.
   

Do not use the portal if it requires a false or incriminating appeal reason.

Suggested reply to CE:

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]

Send that reply, attach the screenshot of the defective dropdown menu, keep CE’s response, and do not engage with any useless and powerless debt collector if CE tries to bypass POPLA. The ANPR admission is likely to be a useful POPLA point.

[3Sh3roo]

Thanks for that, it seems that they were trying to advise the correspondence has NOT been identified as an appeal as they continue to get me to use their portal? Or have I read it wrong? 

Either way, it works very well in my favour, email and image sent. Let's see what happens now.

[b789]

You have read the practical effect correctly, but their wording is badly drafted.

They say the correspondence "has been identified as an appeal", but then they refuse to process it through the complaints route and try to force you back to their defective appeal portal. That is internally contradictory and helps rather than harms your position.

The key point is that they now know the keeper is trying to appeal. They also know why the portal cannot properly be used, because the mandatory drop-down options do not allow a keeper appeal based on PoFA, no keeper liability, signage, contract formation, or lack of evidence. They cannot fairly obstruct the appeal route by forcing the keeper to select an inaccurate option.

For now, wait and see what they do. If they cancel, fine. If they reject and issue a POPLA code, the POPLA appeal can rely on PoFA 9(2)(a), inadequate evidence, signage/contract formation, and the defective appeal process. If they refuse to process it and later try debt recovery without issuing a POPLA code, that becomes a BPA complaint point because the keeper attempted to appeal and CE obstructed the process.

[3Sh3roo]

Hi, today the driver received a reminder as follows, should they respond?

[b789]

Email the following response:

Send to: dataprotectionofficer@ce-service.co.uk
Cc: complaints@ce-service.co.uk, office@ce-service.co.uk, Legal3@ce-service.co.uk

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]