There is an obligation at law to disclose what information you have as to who the driver was. Failure to do so and your in deep lumber even if, as you say, you were not the driver but do not name daughter..
You will have to enter her details on the section 172 form and return it. Consider also sending with it a letter of explanation that she is a resident of Spain that was on holiday and dual Insurance taken out re hire of car.
A word of warning. be absolutely sure that what you have posted is the truth. They may make certain enquiries to confirm what you say and I hope the photo doesn't show a male driving. If so your in deep trouble and can be aligned for attempting to pervert the course of justice. Others have tried this scam and have received prison sentences.
As to what they do when they have her name I cannot say but there is no procedure for service of a Conditional Offer or summons in Spain for UK offence of speeding.
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