Having examined the notice I would say that they are going to claim that this is PoFA compliant even though this is airport land.
It makes no odds at this point as we are going to send them a simple response to their previous letter in order to move the matter forward.
Send the following letter back to VCS in response to their previous letter;
To whom it may concern,
Thank you for your previous letter - I have duly notice its contents.
I write as the Registered Keeper of the vehicle in question.
In this instance I will not be supplying any driver details (either now or at any point in the future) as the law does not require it.
As you are no doubt aware, no adverse conclusion can be drawn in a situation where I exercise my right to say nothing in a circumstance where the law does not require it.
As I understand it, there is no possible way that a vehicle driver could have entered into a contract with VCS in the manner which you appear to claim.
I am sorry that I cannot help you further.
Best wishes,
xxxxx xxxxxxxxx