"If the relevant manager considers that there maybe evidence of a breach then the first action to be taken is initiation of the CEP (see Chapters 2 and 3)".
Think about that for a second.
What we do need to know is the basis of an unqualified "office" manager's (admin, load control etc.) decision that part 20 A (for anything) of the Act has been breached. It's a hell of a call:
From this 'informed' decision being made, all hell is let loose, on one mans say so. It's a stock standard, catchall bluff from Sleepy Hollow; they know the impact but they also know just how hard it is to prove at law. But, none of that matters; they have a "suspected" breach, which lets the dogs out.
Now, you may suspect chemtrails, alien life forces, or the way your Grannies tea leaves fall dictate the fate of the universe. You are quite entitled to believe in Santa, the Easter bunny or even that all politicians are honest; but, you cannot prove it too easily. So why, on the whim of one man, is such a mighty pony pooh storm able to be called down? Who is this masked man?
The brakes need to applied before any such "decision" is made; that suspicion needs to be better than a whim or a 'standard departure' point for the AAT. Before a 'manager' is allowed this much horsepower a case should be presented; the cops can't get a search warrant without reasonable grounds, so how come some office wallah can decide that a serious criminal investigation can be initiated.
I refer you to Macbeth Act 4 scene 1 to discover the way in which these matters are arranged, I reckon the three witches were closer to being legally concise than the 'masked manager' and his crew. Talk about foxes in chook houses.
Selah.