Forgot to Update V5C and received a PCN

fisherjim

SumySani said:

 DCBL believe the data should continue to be held for the purposes of Debt Recovery action due to the case still being live, therefore DCBL are unable to erase your data.

Well that's also rubbish as you don't actually have a debt only an invoice which you dispute.

Trainerman

SumySani said:

Just latest Update
Sent the emails to the DPO as suggested. The email was sent to CEL ( Civil Enforcement Ltd ) using the email address from the privacy on website and also sent to DPO at DCBL. I got 2 replies but both have come from the DCBL - Debt Collectors.

First email response:

Thank you for your email.

DCBL are instructed by our client for debt recovery, we can not get involved in any discussions between you and the client regarding that matter.

Second email response:

Thank you for your email.

DCBL have the correct primary address of XXXXXXXX, XXXXXX ,XXXXXXX held on file.

We can not delete any previous addresses held on file while legitimate interest for processing the data on file remains. Under GDPR, the right to erasure does not apply under certain conditions.

DCBL have considered whether or not the information should be erased and have concluded that in accordance with Article 17 (1) of the GDPR, DCBL are unable to comply with this request due to the fact that the personal data is necessary for the purpose which it was originally collected. DCBL believe the data should continue to be held for the purposes of Debt Recovery action due to the case still being live, therefore DCBL are unable to erase your data.

Once the case is closed with DCBL you may request for all data to be deleted.

Both emails have come from DPO @ DCBL, CEL have not responded, unless they are using DCBL email for their correspondence.

Is there anything further I need to do ?

Is that not tantamount  to an admission that they want to send debt recovery and then legal letters to an address that you have told them will not reach you?

Their whole Court "get a default judgment on the sly" model  laid bare

SumySani

Will do thanks,

If I annoy them,  they'll purposely chase for vengeance

B789

SumySani said:

Will do thanks,

If I annoy them,  they'll purposely chase for vengeance

If you "annoy" them, it can only be good. Seriously though they are unable to get "annoyed" because there is no human involvement for that to happen. This is all handled automatically. Any human involved is undoubtedly intellectually malnourished and serves them right for being a part of the scam.

You should email the DPO back and inform them that they must erase your old address as an address for service and to update it with your current address. Failure to confirm that they have done so will lead to an immediate complaint to the ICO. Give them 3 working days to confirm.

SumySani

Apologies, I wasn't clear in my previous message.
The DPO @ CEL have not responded since the only replies I am getting is from the DPO @ DCBL.

DCBL does my have current correct address. They are saying that they will not erase the old address as stated above.  DCBL somehow managed to find my current address and hence when I first got the letter from DCBL, that was when I realised that we had a PCN against us. 

What I don't understand is that I sent an email to CEL DPO, however the email replies are coming from DPO @ DCBL.

However, when I sent the email for rectification I sent it to both DPO at DCBL and DPO at CEL.

I'm happy to send  a reply to DPO @ DCBL as CEL have not responded as of yet.

Coupon-mad

I say just wait for the case to move to DCB Legal and cheerfully await the court claim and you'll win.  Almost certainly without a hearing.

Le_Kirk

Which address are you using for Civil Enforcement?
I have this: -
dataprotectionofficer@ce-service.co.uk

SumySani

The email address from Le_Kirk post is the address I used to send to CEL DPO.
However, the replies I am getting are coming from DPO@DCBLTD.COM

It seems that DCBL are replying on behalf of them or the CEL email address is actually linked directly to DCBL

SumySani

Just got an email reply from DPO @ DCBL.

They have reviewed my  file and confirmed that they have deleted the old address from their system.
Still nothing from DPO at CEL as of now.

Any further actions I need to take

Le_Kirk

Complain to the ICO that CEL are not complying with the rules, provided it has been one calendar month since you submitted the SAR.