p.37 refers to legal remedies being available to hold the keeper liable. p.41 states that their position is that they can hold the registered keeper liable.
I'd say that's pretty conclusive that they are relying on POFA.
Regards the notice to driver - they mention in their WS that this was issued and that evidence of such is exhibited. What have they disclosed in relation to this?
Don't touch them owe me £500 since January 2019 make excuse after excuse. Seem they always have software problems sending money out. Keep saying they will call back or email nothing been chasing it now for 6 mths the phone staff always have the same banter we will chase it up and get back to you then nothing!