Free Traffic Legal Advice

You don't pay a scammer like VCS. What you have received is speculative invoices for alleged breaches of contract by the driver from an unregulated private parking firm of ex-clampers. As the location (LJLA) is not relevant land for the purposes of PoFA, they cannot hold the known Keeper of the vehicle liable for any charge incurred by the unknown (to them) driver.

Also, as the invoices are for an alleged brach of contract by the driver, what contract do you think that is? The signs at LJLA are not contractual as they are prohibitive. A prohibitive sign cannot form a contract because a contract has to offer something in return for a consideration.

FOr now, you should edit your post to remove any 'foot in the mouth' mission that the Keepr may have also been the driver. Only the Keeper can respond to the Notice to Keeper (NtK). Any correspondence can only be by the Keeper and any mention of the driver must be in the third person only. No "I did this or that", only "the driver did this or that".

For now, you appeal both PCNs separately but with the identical appeal. You only appeal as Keeper. There's no legal obligation of the Keeper to identify the driver to an unregulated private parking firm.

Use the following text for your appeal as the Keeper only separates for each PCN:

Quote

I am the registered keeper. VCS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, VCS will be well aware that they cannot use the PoFA provisions because Liverpool John Lennon Airport (LJLA) is not 'relevant land'.

If LJLA 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 VCS is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for VCS’s own profit (as opposed to a bylaws penalty that goes to the public purse) and VCS 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. VCS have no hope should you attempt to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.

KADOE point (duplicate DVLA requests)

The DVLA’s KADOE framework requires a separate, valid ‘reasonable cause’ for each lookup and data minimisation. Two lookups for what is, in substance, one brief episode minutes apart is arguably not a fresh reasonable cause and can be framed as a KADOE breach (and a data-protection concern).

DVLA SAR now (free): ask for the dates/times and recipients of any disclosures of your keeper data relating to both PCN numbers and your VRM for the relevant period.

If it shows two near-identical disclosures, file a Step 1/Step 2 DVLA complaint and, if needed, an ICO complaint. You can then deploy this in your pre-action reply/court as evidence of unreasonable conduct and misuse of data.