Where does this third PCN come from? I see no reference to anything but 2 PCNs in their correspondence.
ParkingEye are trying to create a “procedural failure” by saying you were granted 7 days to appeal and you did not use it. That is a nonsense position in your circumstances.
You already set out the appeal point in your formal complaint: you never received any Notice to Keeper, therefore no PoFA keeper liability can apply, and the driver will not be identified. Under the PPSCoP, a complaint about a parking charge must be treated as an appeal. So there was no need for you to submit a separate appeal within any arbitrary 7-day window.
More importantly, ParkingEye’s own email effectively concedes that the NtKs were sent to the wrong address. In those circumstances, they cannot lawfully rely on PoFA to pursue you as keeper. They also cannot “fix” that by simply pushing the matter to debt recovery.
What they should have done once you made them aware that the NtKs were not served is simple:
• Either cancel the charges, because keeper liability cannot be created without a properly served NtK; or
• If they wanted to continue pursuing the keeper (which they can’t under PoFA in this scenario), they would need to reissue fresh notices to the correct address and give the keeper the normal opportunity to challenge them. At that point, the keeper is entitled to a fair appeal window (not a made-up 7 days), and if rejected, a POPLA code.
In short, the “7 days” point is a distraction. Your appeal already exists in the complaint, and the substance is fatal to their case: no served NtK + driver not identified = they cannot hold the keeper liable.
If ParkingEye want to waste money, let them. Your response now should force them to either cancel or issue POPLA codes. POPLA will not uphold keeper liability where the driver is not identified and PoFA conditions were not met.
Respond to ParkingEye/CPP with the following:
Subject: Formal complaint was the appeal (PPSCoP) – NtK not served – no keeper liability – cancel or POPLA
Dear ParkingEye Complaints Team,
PCNs: [list all PCN references]
Vehicle registration: [VRM]
Your email confirms that correspondence for the PCNs was posted to my previous DVLA address and that you only amended my address after my contact in December. That is the core issue: the Notices to Keeper were not served at my correct address for service.
As I stated in my formal complaint, because no Notice to Keeper was served on me within the relevant period in accordance with Schedule 4 of the Protection of Freedoms Act 2012, you cannot transfer liability to me as Keeper. The driver has not, and will not be identified.
You also claim that although you granted “late appeal” access on 08/12/2025, no further appeal was submitted within 7 days. That point is irrelevant. The appeal point was already made in the formal complaint, and under the Private Parking Single Code of Practice a complaint relating to a parking charge must be treated as an appeal. There was therefore no requirement for a separate appeal submission within an arbitrary 7-day window.
Once you were put on notice that the original NtKs were not served, you should have either:
1. Cancelled the PCNs, as Keeper liability cannot arise without a properly served NtK; or
2. If you wished to continue pursuing the matter, issued fresh notices to the correct address and afforded the Keeper the proper opportunity to challenge each notice (including, if rejected, the issue of POPLA verification codes).
Instead, you have attempted to close the complaint and divert the Keeper to debt recovery. I will not engage with DCBL. They have no standing and will be ignored.
You must now do one of the following for each PCN:
A) Confirm cancellation; or
B) Issue a valid POPLA verification code for each PCN.
If you refuse to cancel and refuse to issue POPLA codes, while continuing enforcement despite the admitted non-service of the original NtKs, I will escalate this matter to the BPA AOS Compliance Team and the DVLA as a clear breach of the PPSCoP and continued misuse of Keeper data.
For the avoidance of doubt, POPLA will be informed that the driver remains unidentified and that you cannot rely on PoFA keeper liability due to non-service.
Data rectification/erasure – your responsibility
You state that if I require DCBL to make changes to personal data I should contact them directly. That is incorrect.
ParkingEye obtained my data from the DVLA and instructed DCBL to process my personal data for enforcement. ParkingEye is therefore responsible for ensuring that any third party acting on your behalf processes accurate data and that any old/incorrect address data is rectified and erased. You do not discharge your obligations by telling the data subject to chase your agent.
Accordingly, you must confirm, in writing, that:
a) my current address for service has been updated on all of your systems; and
b) you have instructed all third parties/agents you have engaged (including DCBL) to update my address and permanently erase any old/incorrect address data from their records.
Yours faithfully,
[Keeper name]
[Address for service]
[/list]
Email the following to ParkingEye/CPP and CC aos@britishparking.co.uk; data.sharing@dvla.gov.uk and yourself:
FORMAL NOTICE – LIVE COMPLAINT / IMPROPER DEBT RECOVERY ESCALATION
Dear ParkingEye Ltd/Car Parking Partnership,
PCN: 438913/539865
Vehicle registration: [VRM]
Location: University Hospital Coventry / Drop off & pick up
Date of alleged contravention: 04/09/2025
I write as the registered keeper.
On 08 December 2025 I submitted a formal complaint via your complaints process. You acknowledged receipt and confirmed that a response would be issued within 28 days, in accordance with your complaints policy.
That complaint remains live and unresolved.
Despite this, you have instructed Direct Collection Bailiffs Ltd (DCBL) to pursue the parking charge and to issue further payment demands. This escalation while a complaint is under active consideration is improper and is contrary to the Private Parking Single Code of Practice.
I will not engage with DCBL. They have no standing in this matter, are not a party to any alleged contract, and any correspondence from them will be ignored.
You are now on notice that the continued processing of my data for enforcement purposes, and the continuation of debt recovery activity while a complaint is ongoing, will be treated as a breach of the PPSCoP.
If debt recovery activity is not immediately suspended pending the outcome of the complaint, I will escalate this matter without further notice to:
• the British Parking Association (AOS Compliance),
• the DVLA (misuse of keeper data and failure to adhere to the applicable Code of Practice), and
• the Competition and Markets Authority (for unfair commercial practices, including the use of debt recovery to pressure payment during an unresolved complaint).
For the avoidance of doubt, the keeper is under no legal obligation to identify the driver and I decline to do so.
All correspondence must be addressed directly to me at the address for service below or by email.
Yours faithfully,
[Keeper name]
[Address for service]
[email address]
You can safely ignore anything from DCBL. It is just a powerless debt collector trying to intimidate you into paying out of ignorance and fear. Shred the DCBL letters and use the result as hamster bedding for all anyone cares.