PCN Civil Enforcement Spring Hall Medical Practice, Halifax

[b789]

Reply to the clearly, mentally deficient thugs at CEL with the following:

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]