Civil Enforcement Ltd

Idontthinkso2025

Good evening all. I am a newbie so please if I have posted in the wrong place etc don't shoot me. 

Back in 2022 I attended the birches car park in Swanley. The car park was having building work done (building a nursery) There was no electricity on site, pitch black, thick fog and Baltic weather conditions which ended in thick snow falling. I have a blue badge and this was displayed.  Many people parked in the car park alongside me we was all attending a birthday party.
The signs were so high up and in pitch black darkness and fog noone could read them. Noone paid to park we it was a Sunday and couldn't read the signs.

We all received fines. We all appealed. Everyone has their fine cancelled. Except me. Typical. 

Fast forward and it's now going to court. I have completed the NC180 and returned. I just want some advice as to what to do next and or what to expect..and any advice on where I stand.

Not to be woe is me..but I am a disabled mother who had her children in a pitch black park in snow and fog, couldn't see a thing it was awful. The fact everyone's was cancelled except mine has got my back up.  The enforcement company is civil enforcement ltd, looking at reviews says it all.  Thanks in advance

Coupon-mad

Idontthinkso2025 said:

Good evening all. I am a newbie so please if I have posted in the wrong place etc don't shoot me. 

Back in 2022 I attended the birches car park in Swanley. The car park was having building work done (building a nursery) There was no electricity on site, pitch black, thick fog and Baltic weather conditions which ended in thick snow falling. I have a blue badge and this was displayed.  Many people parked in the car park alongside me we was all attending a birthday party.
The signs were so high up and in pitch black darkness and fog noone could read them. Noone paid to park we it was a Sunday and couldn't read the signs.

We all received fines. We all appealed. Everyone has their fine cancelled. Except me. Typical. 

Fast forward and it's now going to court. I have completed the NC180 and returned. I just want some advice as to what to do next and or what to expect..and any advice on where I stand.

Not to be woe is me..but I am a disabled mother who had her children in a pitch black park in snow and fog, couldn't see a thing it was awful. The fact everyone's was cancelled except mine has got my back up.  The enforcement company is civil enforcement ltd, looking at reviews says it all.  Thanks in advance

We're 100% on your side!

Show us the claim form with the same 4 things covered that you see in other claim threads. Read ten or more first.

And show us the defence you put in.

And show us a link to the place on Streetview.

Idontthinkso2025

I'm unable to post a link due to being a Newbie apparently; 

Idontthinkso2025

im so upset with myself that I didn't reach out for advice before doing the defence but I panicked 

KeithP

Here's a GSV link... maps.app.goo.gl/fhHPBPMpJeWfX8Zh6

But nothing newer than October 2014 on GSV.

Coupon-mad

Complain to the DVLA that DCB Legal have (yet again) put into a boilerplate claim form Particulars that the Defendant is being pursued under the POFA, in a case where the POFA does not apply because it is a Council car park (this is not relevant land).

Remind the DVLA that they reportedly (in the public domain) investigated a VCS claim just months ago in 2024 which had used the same DCB Legal boilerplate POFA wording. The DVLA were reportedly satisfied with the apparent excuse that it was a one-off mistake and that DCB Legal were going to 'amend the claim', which the Defendant in that case stated did not happen (the Defendant apparently won the case anyway but said no claim Particulars amendment happened).

In this case, DCB Legal has done it again and it is believed that ALL their (100,000+ per year) parking claims - certainly all seen in the public domain - are always pleaded with this exact boilerplate POFA/keeper liability wording. This cannot continue.

There must be a significant number where the NTK was non-POFA in wording and/or the land was not 'relevant land'.  This is not a one-off or rare situation. Perhaps as high as 5%?  The DVLA will know more or less, from GIAA audits.

The DVLA must re-open the investigation and this time specifically investigate the arrangements before and after DCB Legal receive PCN data in bulk for the purpose of litigation.

This is a complaint about DCB Legal.

There are two concerns, one based on an educated guess (opinion/suspicion arising as a result of the pattern of conduct seen) and one evidence-based:

1.  Firstly, there is this question: could it be that this might be a model akin to 'Debt Assignment'? The way these cases are being churned out might make a reasonable onlooker wonder if DCB Legal could perhaps be (allegedly) attracting clients into expecting a certain % return for the bulk data (seems unlikely, but I wonder, could there be an up-front or early bulk payment?) at or around the point of transferring multiple thousands of data sets from operators for litigation.

It is stressed this is an opinion and educated guess only. But the above point is a question for the DVLA which has arisen after careful observation of a pattern, and for several reasons:

- several operators have moved their business from other bulk litigators to DCB Legal recently and two (ParkingEye and Civil Enforcement Ltd) have even signed deals with DCB Legal to litigate bulk caseloads, despite having their own in-house litigation teams. One wonders why, and given that this claim involves Civil Enforcement Ltd, the complainant urges the DVLA to scrutinise the exact arrangement and find out what it was that incentivised CEL to use DCB Legal rather than their own litigation team for my claim as part of a bulk transfer to DCB Legal, and

- DCB Legal often settle for as low as £10 or £20 at court Mediation stage (without appearing to pause to consult their client during mediation) which other roboclaim legal firms don't, and

- when people defend a case, DCB Legal seem to be in absolute full charge of the 'debt' and will routinely discontinue (a lot), as seen time and again in cases involving multiple different operators. Close to 500 discontinuances have been noted in recent months by DCB Legal, and evidence of those discontinuations is in the public domain and is again, something very rarely seen from other bulk litigators, and

- when operators are asked for a SAR once a case is already at court with DCB Legal, operators have replied more than once that they no longer hold the data.  Not even a picture of the NTK is held, operators say. It seems that Zatpark or similar software is exporting and/or fully transferring the whole data file to DCB Legal automatically, with (it seems) little or no human checks as to whether the case was POFA-reliant, or not.

This last point is despite the fact that the data controller (as described under the Data Protection Act 2018) of DVLA keeper data is supposed to remain the parking operator at all times. And despite the fact that such keeper data may only be used for the purpose for which it was provided, which in all non-POFA cases is solely to invite and ask the keeper to name the driver.  The keeper cannot become liable nor can they be misled that they are liable/that Schedule 4 of the POFA applies.

Why should the DVLA look at this?

Because if the DVLA scrutiny uncovers some sort of (alleged) incentive or perhaps a minimum % return expected per bulk data set (not directly related to, nor dependent upon, case outcomes?), and if it is the case that keeper data is effectively being fully transferred over to DCB Legal, the DVLA should seriously consider whether the arrangement breaches the KADOE data rules. These rules specifically ban 'Debt Assignment type' arrangements (whether arrangements use that word 'assignment' or not) and KADOE also does not allow DRAs or third parties to assume the role of data controller. They must only be agents.

2. Secondly, this case shows that DCB Legal is - on the evidence - failing to plead 'non-PoFA' cases properly and their template Particulars of Claim are continuing to mislead motorists. It is no good the DVLA being robust with operators at GIAA audit stage to make sure non-PoFA cases are not dressed up in NTKs, reminders or rejection letters to mislead that the keeper is liable under the POFA, if no such safeguards are required of the DRAs and bulk litigators when the keeper data is passed to them.

The complainant believes and formally requests that the DVLA should look into suspending DCB Legal from processing DVLA keeper data, not least due to the repeated misleading of motorists (and the courts) when they are sued in non-POFA cases.

Non-POFA NTKs must no longer be pleaded in court claims in the usual DCB Legal boilerplate way, because it misleads the recipient about keeper liability. This is a breach of the CPUTRs (a misleading action or omission) which would be illegal as well as a KADOE breach. The DVLA cannot allow any DRA or legal firm to mislead keepers about liability at any stage of processing, even if it has arisen due to new software transfer capability, negligence and/or a roboclaim MO where (it seems) nobody checks.  That is no excuse.

At the moment no DCB Legal claims are seen (at all) which do not mention keeper liability/POFA and that cannot continue. DCB Group must demonstrate that they will in future check the POFA status of a case before issuing any pre-court threatograms or court claims.

Coupon-mad

The above is my suggested complaint, based on my own observation of the pattern of the DCB Legal MO and my own concerns, suspicions and opinion, which I know is shared by others like me.

It would be good to insist that the DVLA must investigate both concerns. About time...

Idontthinkso2025

Thank you! I will get onto DVLA today! Do you happen to know the best contact in which to send the above?

In regards to my case. Once I have spoken to DVLA I'm guessing this won't be passed on to the courts. What chances do I have of winning this? And do I need to say/do anything in particular in order to win. 

Many thanks for all your help so far

Idontthinkso2025

Ignore the above. Email sent to all relevant departments

Idontthinkso2025

To add to this, I received the attached email from DCB legal. Staying they had attached their clients NC180. Yet it is completely blank? No boxes are ticked? 

Gr1pr

Check your MCOL claim history to see if the CNBC in Northampton has posted a blank N180 to you