Interesting. I assume those are their "evidential" photos. All of them have exactly the same timestamp of 18:21:27. "Evidence" perhaps that the operator has simply pasted the same timestamp on to all the photos?
Without a valid "period of parking" on the Notice to Keeper, it is not fully compliant with all the requirements of PoFA to be able to hold the Keeper liable, as long as the drivers identity is not revealed. There is no legal obligation for the Keeper to identify the driver to an unregulated private parking company.
NPC will always reject an initial appeal, no matter what is put in it and there is little hope that an IAS secondary appeal will succeed either. However, they would be confirming their intellectual malnourishment if they were to ever try and litigate on this in the county court.
For now, simply appeal only as the Keeper with the following:
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. NCP 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.
Should you insist on pursuing this PCN, I will not hesitate to escalate this matter to the IPC as your evidential photos all bear the exact same timestamp of "2024-11-23 18:21:27", which is impossible unless your operative is either Flash Gordon or they have been tampered with. Which is it? I am sure that the media would be very interested also.
So, as NCP have no hope at IAS, you are urged to save us both a complete waste of time and cancel the PCN.