You won't get a Letter of Claim (LoC). Ignore DRP. They are a powerless debt collector with no standing with regards to the alleged breach of contract by the driver.
What you MUST do is notify APCOA of your address change. you can do that and complain/appeal the PCN in one fell swoop by sending the following to the APCOA DPO by email to dpo@apcoa.com and CC yourself:
SUBJECT: DATA RECTIFICATION NOTICE (ARTICLE 16 UK GDPR) – FOLLOWED BY FORMAL COMPLAINT/KEEPER DISPUTE
Dear APCOA,
PCN reference: [if known]
Vehicle registration: [VRM]
DATA RECTIFICATION NOTICE – ACTION REQUIRED
I am the registered keeper of the above vehicle.
You are processing my personal data inaccurately. My address for service has changed. With immediate effect, you are required to:
1. Erase the old address you are currently using for all processing purposes
2. Replace it with the correct address for service shown below
3. Confirm in writing that rectification has been completed
4. Ensure all third parties (including but not limited to debt recovery agents) are instructed to erase the old address and use only the corrected address
Correct address for service:
[insert full address]
Processing or sharing my data using the incorrect address after receipt of this notice will constitute unlawful processing.
Once this data rectification has been actioned, the remainder of this correspondence must be passed to the appropriate department and treated as a formal complaint / dispute of liability.
FORMAL COMPLAINT/KEEPER DISPUTE (SECONDARY)
I am the registered keeper. APCOA cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, APCOA will be well aware that they cannot use the PoFA provisions because Stansted Airport is not 'relevant land'.
If Stansted Airport wanted to hold owners or keepers liable under Airport Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because APCOA is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for APCOA’s own profit (as opposed to a bylaws penalty that goes to the public purse) and APCOA has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. APCOA have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
IMPORTANT
This correspondence contains two distinct elements:
• a Data Rectification Notice, which must be actioned immediately; and
• a formal keeper dispute, which must be passed internally once rectification is complete.
Any attempt to ignore the dispute on the basis that this is “only” a data request will be treated as a failure to deal with a complaint.
Yours faithfully,
[name]
APCOA are not litigious and will not issue a claim but you must still cover every eventuality and send the above email.