About Us

A trusted outsourcing provider with legally qualified Leadership

We understand that reputation is crucial in an industry that has the potential to damage reputations due to legally flawed processes and negative public perceptions.

At District Enforcement, our emphasis is on ethical and legally sound processes backed with accountability and transparency. Our core purpose is to protect the shared value, rights and environments enjoyed by society.

This is what we do, day in day out, legitimately, reasonably and with respect.

The industries we work within are unique. That is to say the end-user of our service is often not the individual or organisation who has engaged with us for our compliance services in the first instance.

Therefore, we clearly differentiate between our Clients: landowners, local authorities, businesses, etc., and our Customers: those who pay either through their ‘wrong doing’ (e.g. received a penalty notice, mooring charge or parking charge), or those who utilise our paid-for services.

Our people recognise the need to act fairly, legally and with moral integrity regardless of whether they are engaging with a Client or a Customer. They understand the need for sensitivity and to be respectful and considerate, or when to take a firmer stance when required to do so.

Our enforcement processes are carefully formulated from a legal and ethical perspective, and are designed to achieve high compliance rates without the need for misleading or coercive tactics.

These principles are embedded in the ethos of our operations – beyond just words – and putting fairness into action.

Introduction

This policy applies to:

• All employees of this Company;
• All regional staff or home workers operating on behalf of this Company.

This policy is operational from 25 May 2018.

Purpose

The purpose of this policy is to enable the Company to:

• Comply with our legal, regulatory and corporate governance obligations and good practice
• Gather information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
• Ensure business policies are adhered to (such as policies covering email and internet use)
• Fulfill operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking
• Investigate complaints
• Check references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
• Monitor staff conduct, disciplinary matters
• Market our business
• Improve services

Scope

This policy applies to information relating to identifiable individuals e.g. staff, applicants, former staff, clients, suppliers and other third-party contacts.

We will:

• Comply with both the law and good practice
• Respect individuals’ rights
• Be open and honest with individuals whose data is held
• Provide training and support for staff who handle personal data, so that they can act confidently and consistently

We recognise that its first priority under the DPA is to avoid causing harm to individuals. In the main this means:

• Complying with your rights,
• Keeping you informed about the data we hold, why we hold it and what we are doing with it,
• Keeping information securely in the right hands, and
• Holding good quality information.

Secondly, DPA aims to ensure that the legitimate concerns of individuals about the ways in which their data may be used are taken into account.  In addition to being open and transparent, we will seek to give individuals as much choice as is possible and reasonable over what data is held and how it is used.  This includes the right to erasure where data is no longer necessary and the right to rectification where the data is incorrect.

Full details are available in the Privacy Notice issued at the point of gathering the data and on our website.

Risks and Controls

The Company has identified the following potential key risks, which this policy is designed to address:

• Breach of confidentiality (information being given out inappropriately).
• Insufficient clarity about the range of uses to which data will be put — leading to Data Subjects being insufficiently informed
• Failure to offer choice about data use when appropriate
• Breach of security by allowing unauthorised access.
• Failure to establish efficient systems of managing changes, leading to personal data being not up to date.
• Harm to individuals if personal data is not up to date
• Insufficient clarity about the way personal data is being used e.g. given out to general public.
• Failure to offer choices about use of contact details for staff, clients, workers or employees.

In order to address these concerns, to accompany this policy, we have an accompanying Information Security policy and we will issue Privacy Notices to explain what data we have, why we have it and what we will do with it.  The Privacy Notice will also explain the data subject’s rights.

We will offer training to staff where this is necessary and appropriate in the circumstances to ensure compliance with DPA. Such training will vary according to the role, responsibilities and seniority of those being trained.

We aim to keep data only for so long as is necessary which will vary from according to the circumstances.

We have no intention to transfer data internationally.

Responsibilities

The person responsible for Data Protection is currently Dyl Kurpil with the following responsibilities:

• Briefing the board on Data Protection responsibilities
• Reviewing Data Protection and related policies
• Advising other staff on Data Protection issues
• Ensuring that Data Protection induction and training takes place
• Notification
• Handling subject access requests
• Approving unusual or controversial disclosures of personal data
• Approving contracts with Data Processors
• Ensuring Data is stored securely
• Maintain a Data Audit and keep this up to date
• Reporting breaches to the Information Commissioners Office and the relevant Data Subject(s)

Significant breaches of this policy will be handled under the Company’s disciplinary procedures which may amount to gross misconduct.

Subject Access Request

Any subject access requests will be handled by District’s Data Team.

Subject access requests must be in writing.  All staff are required to pass on anything, which might be a subject access request to dpo@district-enforcement.co.uk without delay.  The applicant will be given their data within 1 month unless there are complexities in the case which justify extending this by 2 months.  You will be notified of any extensions to the deadline for response and the reasons as soon as possible.

We have the right to refuse a subject access request where data is requested at unreasonable intervals, manifestly unfounded or excessive.  You will be notified of the reasons as soon as possible.

Where the individual making a subject access request is not personally known to District’s Data Team, their identity will be verified before handing over any information.

The required information will be provided in a permanent and portable form unless the applicant makes a specific request to be given supervised access in person.

You have the right to request the information we hold is rectified if it is inaccurate or incomplete.  You should contact dpo@district-enforcement.co.uk and provide with the details of any inaccurate or incomplete data.  We will then ensure that this is amended within one month. We may, in complex cases, extend this period to two months.

You have the right to erasure in the form of deletion or removal of personal data where there is no compelling reason for its continued processing.  We have the right to refuse to erase data where this is necessary in the right of freedom of expression and information, to comply with a legal obligation for the performance of a public interest task, exercise of an official authority, for public health purposes in the public interest, for archiving purposes in the public interest, scientific research, historical research, statistical purposes or the exercise or defence of legal claims.  You will be advised of the grounds of our refusal should any such request be refused.

To read our full Privacy Policy click here.

District Enforcement Limited – Complaints Procedure (Parking)

This policy identifies District will accept, record, investigate, respond and conclude complaints received.

Complaints are distinct from appeals against Parking Charges issued in that they relate to the conduct or quality of the service received.  Where a “complaint” relates to the issue of a Parking Charge Notice, the relevant appeals process should be followed.

Members of the public may lodge a complaint via email, letter or via the website. Complaints must be recorded in the Complaints register and the following information capture:

1. date of complaint;
2. the complainant;
3. copy of complaint;
4. copy of all correspondence;
5. outcome;
6. details of corrective action required and undertaken to ensure the situation does not recur (where the complaint has merit).

District will maintain a register showing the last 24 months of complaints and in compliance with GDPR.

Complaints must be acknowledged to the Complainant, that they have received the complaint are investigating within 10 working days.   Any investigation must be concluded within 20 working days. Where there are exceptional circumstances for not concluding the complaint within 20 working days, we will write to the complainant and explain why the matter is not concluded and when it will be.  We will write to the complainant when the complaint is concluded.

In addition to the requirements above, where a complaint is received from an MP we will, upon resolution of the complaint, refer the MP to the MP portal on the IPC website. The following statement must be included in any response to an MP:

“We are members of the International Parking Community (IPC) Accredited Operator Scheme (AOS). The IPC is a DVLA Accredited Trade Association (ATA) and has a Code of Practice and an Independent Appeals Service (IAS) that allows a Motorist access to an independent adjudication process on the lawfulness of Parking Charges issued by their members. An important condition of being an AOS member is that operators must adhere to The Code. If you are not content with the response, we have provided you with, you can refer this to the IPC who will investigate and provide you with a response. To make this process as simple as possible the IPC has created a communication portal on their website https://theipc.info/login for you to use. They have created a username for all members of Parliament. Your username will be your email address. An email will have been sent with your login details. There is an option for you to reset your password if you are unable to login. If you have any issues, please contact the IPC via email on mp.enquiries@theipc.info.”

Details of the process to be followed are contained below:

1. On receipt of a complaint either by email or postal, a reply of acknowledgement must be sent to the complainant within ten working days.
2. The complaint must be concluded within 20 working days ensuring that the complaint forms no part of an appeal previous/current. Where there are exceptional circumstances if the matter is not concluded within 20 days the complainant must be informed of when the matter will be fully resolved.
3. Information must be recorded into the complaints log along wih all documents relating to the complaint and stored for 24 months.
4. Within the reply we must inform the complainant that if they are disatisfied, they have the right to escalate their complaint to a “Tier 2” where we will review the complaint again internally.
5. If a further complaint is submitted, this must be concluded within 20 working days. Within the reply to conclude the complaint we must inform the complainant of their right to further their complaint if still dissatisfied to the IPC.
6. In addition to the requirements already listed where a complaint is received by an MP, upon resolution of the complaint, refer the MP to the MP Portal on the IPC wesbsite. The statement listed below must be included in a response to an MP.

To find out more or to make an appeal click here.

District Enforcement Limited – Complaints Procedure (Enviro)

This document identifies how District will accept, record, investigate, respond and conclude complaints received.

Complaints are distinct from representations against Fixed Penalty Notices (FPNs) issued in that they relate to the conduct of the Officer or quality of the service received.  Where a “complaint” relates to the issue of an FPN, the relevant Representations process should be followed.

Members of the public may lodge a complaint via email, letter or via the website.  Complaints must be recorded in the Complaints Register and the following information capture:

1. Date of Complaint
2. Date of acknowledgment (must be within 3 working days of receipt)
3. Complainant
4. Outcome
5. Date of reply (must be within 10 working days of receipt)
6. Copies of Complaint on file
7. Client (Council)
8. Comments
9. Details of any escalation to the Council (Stage 2 Complaints)
10. Date concluded (must be within 20 working days)
11. Details of corrective action required and undertaken to ensure the situation does not recur (where the complaint has merit).

District will maintain a register showing the last 24 months of complaints and in compliance with GDPR.

Complaints must be acknowledged to the Complainant, confirming that the complaint is being investigated and a response will be provided within 10 working days.  The Client (Council) is to be provided with details of the Complaint within 3 working days of receipt and the relevant contract manager notified.

Any investigation must be concluded within 10 working days and the Complainant notified.  Where there are exceptional circumstances for not concluding the complaint within 10 working days, the Complainant must be notified in writing with an explanation as to why the matter is not concluded and when it will be.  The Complainant is to be notified in writing when the complaint is concluded.

Due to the partnership working with the Council, the Complainant has the right to escalate their complaint to the Council if they are dissatisfied with our response.  This is called a Stage 2 Complaint.  In these circumstances, all the relevant information must be provided to the Council to review and respond to the complaint.

In addition to the requirements above, where a complaint or representation is received from an MP or elected Councillor, this must be recorded as a Complaint and responded to in accordance with the procedure.

Details of the process to be followed are contained below:

1. Offender writes/emails complaint.
2. Complaint read by nominated member of District’s Ops Support Team.
3. Body Worn Camera footage reviewed, and Officer questioned if needed.
4. Any queries discussed with Team Leader and escalated to Contract Manager/Head of Service where necessary.
5. Council provided with all associated evidence/correspondence within 3 working days and prior to response issued. Time/Date allocated to discuss with Contract Manager if needed.
6. Response by post/email (dependent on how received) no later than working 10 days after receipt.
7. Correspondence and supporting evidence (e.g. witness statements or body-camera footage) saved on system under offender’s FPN number.
8. Complaints about Officers’ conduct are emailed to District’s Compliance Officer and Head of Service. Restorative action undertaken prior to escalation to Council.
9. Stage 2 Complaint heard by Council if initial complaint not resolved.
10. If the FPN was issued incorrectly, District will cancel the penalty and inform the complainant in writing. The issuing Officer will receive immediate refresher training including shadow training. Conduct is regularly monitored, discussed at contract review meetings with the Council and the Officers’ biannual appraisals.
11. All complaints are reviewed by the Senior Management Team to identify trends and to drive continuous improvement.

To find out more, click here.