There is no requirement to explicitly state "Protections of Freedom Act 2012" or similar, but in order to use the legislation to transfer liability there are a number of requirements which need to be satisfied, and in this case they aren't, there are explicit statements which need to be made which aren't made here.
So an appeal can be on the basis that the registered keeper can not be liable in place of the driver, who will not be named, because the requirements of PoFA 2012 have not been met in the notice.
