She has not received an "fine" from CP Plus. CP Plus are an unregulated private parking firm and not any form of authority that can issue "fines" or "penalties". What was sent to her old address was a speculative invoice for an alleged breach of contract by the driver.
DCBL are not a party to the contract the driver allegedly breached. Your mother can safely ignore any correspondence from DCBL. Debt collectors are powerless to do anything except to try and intimidate the low-hanging fruit on the gullible tree into paying up out of ignorance and fear.
What your mother needs to do, or you can do it for her, but in her name (as her) is send a Data Rectification Notice (DRN) to the DPO of CP Plus Ltd and instruct them to
update their records with her
current address for service and to
erase her old address. The highlighted words are there for a reason, so make sure you use them. It should be emailed to them at dpo@groupnexus.co.uk
It is too late for any appeal. However, you can send a formal complaint to CP Plus Ltd, as your mother, as follows to info@groupnexus.co.uk and CC yourself:
Subject: Formal Complaint – Non-receipt of Notice to Keeper and Improper Escalation to Debt Collection
PCN Ref: [PCN ref No. which should be on the debt recovery letter]
Dear Sir or Madam,
This is a formal complaint concerning your handling of the above-referenced Parking Charge Notice. I have received a letter from DCBL demanding payment of £262. This is the first correspondence I have received regarding this matter. At no stage did I receive any Notice to Keeper from CP Plus Ltd, nor was I afforded an opportunity to appeal or pay the charge at the original rate.
The escalation of this alleged debt to a third-party debt collector in the absence of proof of service is procedurally improper, unreasonable, and contrary to Section 11.2 of the Private Parking Single Code of Practice (Version 1.1, 17 February 2025). That section requires you to treat such matters as complaints and suspend enforcement activity until fully resolved.
Accordingly, I now require the following within 14 days:
1. A complete copy of the original Notice to Keeper, including all evidence relied upon.
2. Proof of posting (or other evidence of dispatch) for the Notice to Keeper, showing the exact date and address used.
3. Confirmation that my correct address for service has now been recorded as:
[Insert full correct address]
Unless and until this complaint has been investigated and the requested documentation supplied, you are required to immediately suspend all debt collection activity and instruct DCBL to cease contact.
Should you be unable to produce proof of posting, any reliance on the presumption of service under the Interpretation Act 1978 is rebutted. Continued processing or disclosure of my data to third parties without a lawful basis will amount to a breach of the UK GDPR. This complaint will, if necessary, be escalated to both the British Parking Association (BPA) and the Information Commissioner’s Office (ICO).
Please acknowledge receipt of this complaint and issue a full written response within 14 days.
Yours faithfully,
[Full Name (mum's)]
[Full Address]
[Vehicle Registration]