To: info@dcblegal.co.uk
CC: info@g24.co.uk
Subject: Final Response
Dear DCB Legal,
I refer to your recent correspondence, including your without prejudice settlement offer and your subsequent comments regarding the alleged debt.
It is now the case that every parking charge notice to which your Letter of Claim dated 13th March 2025 referred is statute-barred under Section 5 of the Limitation Act 1980. There is no longer any legal basis upon which you, or your client, can issue a claim or seek to enforce any of these alleged debts through the courts.
Your attempts to solicit payment despite this are entirely without merit and should now cease. Any further demands for payment or threats of legal action will be treated as harassment and reported accordingly.
G24 Parking Ltd is also copied into this response and may wish to reflect on how what was initially presented as a potential claim for a substantial sum has been reduced to a desperate and unenforceable position, due entirely to the incompetence of their instructed representatives.
No further correspondence will be entered into.
Yours faithfully,
[Your Name]
Subject: Response to Letter of Claim – Request for Full Breakdown of Alleged Debt
DCB Legal
Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG
By email to: info@dcblegal.co.uk
[Date]
Dear DCB Legal,
I refer to your Letter of Claim dated 13th March 2025. Your ref: [Their ref number]
I note that you have simply listed six alleged PCNs by date, along with an undisclosed breakdown of a total of £1,020. This fails to comply with the Pre-Action Protocol for Debt Claims (PAPDC), which requires you to provide a clear and detailed explanation of how the alleged sum has been calculated.
Before I consider my position, I require specific answers to the following questions:1. A full breakdown of the sum claimed, including:• The original amount of each Parking Charge Notice (PCN).
• Any additional charges applied, including but not limited to "Debt Recovery" fees or "Damages" per PCN.
• Does any additional sum represent what you describe as a “Debt Recovery costs” and if so, is this figure net of or inclusive of VAT? If inclusive, I trust you will explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.
• Whether interest has been added, and if so, from precisely what date for each PCN.
2. Confirmation as to whether the principal sum of each PCN is being claimed as:• Damages for breach of contract, or
• Consideration for a purported parking contract?
3. If the additional sums exceed the original £100 per PCN, please explain how you or your client justifies these charges in light of the Court of Appeal ruling in Excel Parking v Wilkinson [2022] (G4QZ465V), where the court confirmed that "Debt Recovery" uplifts were an abuse of process?
I would caution both you and your client against simply dismissing these questions with vague or boilerplate responses, as I am fully aware of the implications. By claiming that PCNs are exempt from VAT while simultaneously inflating the debt recovery element, your client – with your assistance – appears to be evading VAT obligations due to HMRC. Such mendacious conduct raises serious questions about the legality and ethics of your practices.
I strongly advise your client to cease and desist. Should this matter proceed to court, you can be assured that these issues will be brought to the court’s attention, alongside a robust defence and potentially a counterclaim for unreasonable conduct.
Yours faithfully,
[Your Name]
Subject: Response to Letter of Claim – Request for 30-Day Hold for Debt Advice
DCB Legal
Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG
By email to: info@dcblegal.co.uk
7th April 2025
Dear DCB Legal,
Re: Letter of Claim dated 13th March 2025 – Reference [Your Reference Number]
I have already acknowledge receipt of your Letter of Claim dated 13th March 2025 regarding the alleged outstanding balance of £1,020.00.
I am currently seeking independent debt advice and, as per the Pre-Action Protocol for Debt Claims, I formally request that you place this matter on hold for a minimum period of 30 days from the date of this letter to allow me sufficient time to obtain advice.
Please confirm in writing that you have placed this matter on hold for 30 days.
Yours faithfully,
[Your Name]
[Your Address]
[Your Email]
Subject: Immediate Rectification Required – Breach of Data Protection Obligations
Dear Data Protection Officer,
I am writing in response to your excessive and unjustified request for sensitive personal documents regarding my Data Rectification Notice (DRN). The only relevant evidence you require is the copy of the Debt Recovery Agent (DRA) letter from DCBL that was sent to the correct address. As the Keeper, my possession of this letter is sufficient proof of both my identity and the correct address.
Your demand for photo identification and financial documents is wholly unnecessary, disproportionate, and a clear contravention of the principles set out in the UK GDPR. Specifically:• Article 5(1)(c) – Data processing must be adequate, relevant, and limited to what is necessary. Your request blatantly exceeds this standard.
• Article 16 – Data subjects have the right to rectification of inaccurate or outdated data without undue burden or delay.
Should you fail to update your records and erase the outdated address, or attempt to initiate litigation to the incorrect address for service despite being informed of the correct address via my DRN, I will not hesitate to take legal action. Should you obtain a default County Court Judgment (CCJ) due to serving a claim at an address you have been expressly notified is incorrect, I will use your unreasonable behaviour as evidence in a counterclaim for damages.
Additionally, I will:1. Report your breach to the Information Commissioner’s Office (ICO);
2. Escalate a formal complaint to your Accredited Trade Association (ATA);
3. Notify the DVLA of your failure to comply with data protection laws, potentially jeopardising your access to Keeper data.
This is your final opportunity to comply promptly with the law and my request. I expect confirmation that my records have been updated and the old address erased within seven (7) days. No further communication will be entertained beyond this timeframe.
Yours sincerely,
[Your Full Name]
Why do DCBL, a useless and powerless debt collector say that "we write further to your email"?????
The first thing you must do, immediately, is send a Data Rectification Notice (DRN) to the G24 DPO instructing them to update their records with your (the Keeper) current address for service and to erase your old address. The highlighted words are there for a reason and you must use them.The very first thing you should do is the above.
Can I request a photo of the vehicle entering the car parkI'm not sure what this will achieve - you seem to accept the vehicle was there.
My partner is also willing to confess she was the driver.Don't do anything yet, but thinking aloud, this could potentially be used tactically, depending on how quick DCB Legal are in getting involved. It would potentially make your girlfriend the defendant rather than you, which I realise you may be keen to avoid, but they'd then have to follow the pre-action protocol with her too, and by the time they got to being able to issue a claim, such time may have passed that the number of charges they'd be able to claim for would be greatly reduced. I'm not suggesting taking that course of action, but it's one to bear in mind as we see how things play out.
However I was not the driver of the vehicle and can prove thisWhether you were the driver may be relevant, but it depends if G24 complied with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 - if they did, then they can seek to recover the charges from you as the registered keeper. The issue is we don't have access to the original notices to check.