I would need to see the Notice to Keeper (NtK) that was sent to your Scottish address. However, at the time of the alleged parking contravention in England, your address on the vehicle logbook (V5C) was in Scotland. Because of this, you were a Scottish resident when the parking company obtained your details from the DVLA and sent you the Notice to Keeper (NtK).
The parking company may have included warnings in the NtK that say you, as the Keeper, are liable under the Protection of Freedoms Act 2012 (PoFA). However, this is legally incorrect.
The law that allows a parking company to make the Keeper liable (if the driver hasn’t paid) is called Schedule 4 of the Protection of Freedoms Act 2012. But this law only applies in England and Wales. It does not apply in Scotland or Northern Ireland. This is clearly stated in the legislation itself.
Because your address at the time the NtK was issued was in Scotland, PoFA does not apply to you for this parking charge. You cannot be made liable as the Keeper under this law, no matter what the parking company says in the NtK.
If you have since moved to England and updated your address with the DVLA, that does not change your legal position. The parking company only had one opportunity to request your details from the DVLA for this particular parking charge, and they did so when your address was still in Scotland. PoFA cannot suddenly apply to you just because you now live in England. Your liability under the law is decided based on your situation at the time the NtK was sent.
However, now that you have moved, it is a good idea to tell the parking company your new address. This is so they cannot send any court paperwork to the old address and try to get a judgment against you by default. To do this, you should send them a formal request to update your current address for service and to erase your old address, using your legal right under UK data protection law. This is called a Data Rectification Notice (DRN). It simply tells the company to correct their records and send any future letters to your new address.
Sending the DRN does not make you liable. It just ensures that if they do take further steps, they send things to the correct place. But your legal position remains the same: you cannot be held liable under PoFA for this parking charge because you lived in Scotland when they obtained your details and issued the NtK.
Of course, the above only applies if you have not identified the driver. The driver who is unknown to the PPC, would remain liable. The Keeper is under no legal obligation to identify the driver to an unregulated private parking company and should not do so, inadvertently or otherwise.
You only refer to the driver in the third person. No "I did this or that". Only "the driver did this or that". SO as long as the PPC does not know the drivers identity, they have no way to pursue this to a conclusion where you could be liable to pay a penny to them.
