Thanks for all this extra info re the company, not sure I totally understand it.
In a nutshell it means this:
When a "request for driver's details" is addressed to an individual and no response (or an unsatisfactory one) is received, the individual to whom it was addressed will, on conviction for that offence see a fine and six points imposed on his licence.
Where the recipient of the request is not an individual but a "body corporate" (e.g. a company) it is not possible to impose points because a company does not have a driving licence or driving record.
However, there is a provision in the law which says if it can be proved that the failure to respond is due to the "consent, connivance or neglect" of an identifiable individual, that individual can also be punished.
So if, in your circumstances, you (as, say, the Company Secretary) decide to say "Sod it. We'll not bother responding to that. I know who was driving but I don't want to see him get an endorsement and points so we'll just take the financial hit against the Company" (and it can be proved) then you, as an individual, can also face prosecution.
It was then suggested that you, as that individual, could also see six points imposed. But as Southpaw points out, the law does not allow it. The only penalty is a financial one.
I don't know what the various sections are on the response form. In essence the Company needs to say "I was not driving" and then provide Dad's details as the person who was. He will then get his own request which he must complete to confirm he was driving.
