You can simply ignore that fishing exercise. Personally, I prefer to mess with the intellectually malnourished minds that get to actually read the response and would respond with the following:
Subject: PCN [reference] – Vehicle [VRM] – Keeper Response
To: APCOA Parking (UK) Ltd
Dear Sir/Madam,
I write as the registered keeper.
Your latest letter is a time-wasting, template fishing exercise. You already know that Schedule 4 PoFA does not apply on airport land governed by byelaws; Stansted is not “relevant land”. You chose to issue a private contractual charge aimed at a driver, not a byelaws penalty. Keeper liability is not available to you.
To be absolutely clear:
• I decline your request to name the driver. There is no legal duty to assist your case.
• Your NtK cannot transfer liability to the keeper.
• Re-asking for driver details will not make an inapplicable statute suddenly apply.
Your options are therefore binary and limited to:
1. Cancel the PCN, or
2. Provide a POPLA verification code so this can be concluded.
If you persist with template demands, or pass my data to any third party while this matter remains contested, I will treat it as misuse of personal data and escalate formal complaints to the DVLA, BPA, and ICO without further notice. I will not correspond with debt collectors.
Kindly spare us both any further boilerplate. Either cancel it or issue POPLA.
Yours faithfully,
[Name]
Registered Keeper