CEL / DCBL – GP practice car park – NtK never received

Poorengineer887

Location: Wales
Operator: Civil Enforcement Ltd (CEL) – BPA AOS
Debt collector: DCBL (letter/phone calls only; no court claim)
Keeper: me (V5C address was only recently updated)
LBC received: No – I have not received any Letter of Claim.

1) Summary / TL;DR

I was a genuine patient at a GP practice on May. I never received the original Notice to Keeper (NtK) or reminders. 2 Months later I first learned about the PCN from a DCBL debt letter traced to my current address.
CEL now says it’s “too late to appeal” and has passed to debt recovery. I’ve asked them to pause debt recovery.
The GP Practice Manager first said they could arrange cancellation, then said they couldn’t. A GP on the phone called it a “fine” and advised me to pay if it caused me mental health issues. I’m seeking advice on next steps (POPLA, BPA complaint, landowner route, and possible small claim vs the practice).

 Key facts & timeline

Event: 05/2025 – attended Medical Centre as a patient

Operator paperwork (per CEL’s recent attachment): NtK dated 31/05/2025; reminders 17/06/2025 and 01/07/2025.

I did not receive those at the time. My V5C address was only recently updated, and I only learned what V5C is used for.

First awareness: DCBL letter in August 2025 (trace to current address).

DCBL calls: I requested email-only due to anxiety; I still received calls on 09/09 and twice on 16/09.

Practice Manager (PM): Initially said “we can arrange to cancel” , later said practice can only intervene within 28 days and I must deal with CEL/DCBL.

GP doctor by phone: called it a “fine” and advised me to pay if this is causing mental health issues.

Health Board: replied that GP practices are independent contractors; suggested Ombudsman/Llais.

My current actions:

• Wrote to CEL: non-receipt; asked for strict proof (posting logs, DVLA KADOE dates/address, signage, landowner authority).

• Wrote to DCBL: dispute, hold and refer back to client; no calls.

• Considering BPA Motorist Complaints if CEL refuses to reopen.

No Letter of Claim received to date.

Site/communication issues

• Patient was unwell; VRM keypad/payment/registration process was not clearly communicated at reception; signage not obvious.

• ANPR entry/exit times ≠ parking period; consideration/grace time unclear.

• Debt-collector add-on fees also a concern.

Question :

Given non-receipt and late discovery, can/should I insist CEL restarts the appeal and provides POPLA, and that debt recovery is paused meanwhile? Any model wording I should add?

No keeper liability? Since I did not receive the NtK/reminders, should I press “strict proof of PoFA Schedule 4 compliance” (posting logs, KADOE date, address used etc.) and only argue no keeper liability if they can’t prove given within 14 days?

Small claim vs GP practice: If the practice refuses to assist (after promising to), is a small claim (negligence/failure to take reasonable steps to communicate patient parking; principal/agent responsibility) a sensible parallel track?

The GP’s phone advice (“it’s a fine, just pay if you’re anxious”) – could that be misleading in consumer/contract terms? (I’m aware “PCN” here is not a criminal/LA fine.) I’ve seen references to Fraud Act 2006 s.2–4 and to consumer unfair-trading regs — do these ever apply in practice to this sort of clinical-admin communication, or is this too ambitious?

Contract formation: is it fair to frame this as no contract (no clear offer/terms brought to my attention; no informed acceptance), hence not a “debt” but a contested contractual claim?

Should I proceed now with a BPA complaint about being told “too late to appeal / passed to debt,” despite late discovery and my request to reopen?

Any help greatly appreciated.

Gr1pr

I doubt that they will reissue the NTK PCN letter if it was your fault that your V5c wasn't updated   ( its a very common error by Registered Keepers  ) , so you can ask, but I bet that they refuse

Pofa2012 is not mandatory,  so there is no 14 days deadline,  the parking companies have 6 months to obtain keeper details and one month to get the pcn to the keeper,  regardless of who was driving. They probably complied with POFA anyway,  by issuing the pcn before day 12

Plan A should have worked,  getting the practice to cancel the pcn,  seeing as they employed the private parking company 

No valid parking contract,  no landowner authority and signage issues are all part of many defences 

The BPA AOS compliance team may look into a complaint,  but I dont think that they will bat for you,  more likely to side with the parking company 

A court claim will eventually resolve the matter 

Definitely do not pay 

Coupon-mad

Yep no paying. Easy to defend, which is the only fair resolution stage you get.

Car1980

I would email both CEL and DCB Legal info@dcblegal.co.uk (not DCBL) and confirm that the correct service is your current address and that you look forward to defending their court claim.

Then you're covered. Very easy for someone at CEL to stick in a court claim at the old address on purpose to gain a default judgment.

Poorengineer887

Much appreciated C!

For context, I already sent the following months ago:

Dear Civil Enforcement Ltd Data Protection Officer,

Please treat this as a correction and update to my data-rights request:

1. Rectification (UK GDPR Art.16) – Set my current postal correspondence address to:
   my adress
   Use this address for all future mail. Please ensure your agent DCBL also updates their records accordingly.

2. Erasure/Restriction of legacy addresses (Arts.17 & 18) – Delete any previous/legacy postal addresses you hold for me from active systems and stop using them for any correspondence or tracing. Where retention is legally required, restrict those records so they cannot be used for contact.

3. Objection to calls (Art.21) – Do not telephone me. Contact email-only going forward. Remove/stop processing my phone number for calls.

4. Confirm & re-issue – Please confirm these updates are completed and re-issue any required notices to the updated address above. I also request the PCN reference and dates/methods of any letters previously issued (redacted copies acceptable).

This correction supersedes any prior instruction that might have suggested erasing my current address.

I sent it to:
dataprotectionofficer@ce-service.co.uk
dpo@dcbltd.com

My concern now: I am not 100% sure they serve any future court claim at my correct address, despite me notifying them months ago. 

Poorengineer887

Feels like a cash-grab. PM refused to help, even though I was a patient. Honestly suspect they’re acting in lockstep with the parking company.