PCN Civil Enforcement Spring Hall Medical Practice, Halifax

[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]