• Our no bullsh*t guide to #Winning at POPIA

    Wanna stay in the Regulator’s good books? We swear by these ten steps. KNOW WHAT TO DO IF THE POPIA HITS THE FAN Suffering a data breach is...

  • The rise of #FUNLAW

    Two lawyers walk into a bar … Only kidding, our jokes are never that predictable. But if two lawyers did walk into a bar, chances are they would drink too much. That’s...

  • When POPIA applies to what we say…

    Is it open season for sharing personal information in conversation, or should we be vigilant about breaching POPIA? WHAT SECTION 3 SAYS To find out if POPIA applies to...

  • Telemarketing in South Africa: Navigating the POPIA landscape

    THE STIR Telemarketing in South Africa is under the microscope, and let's be real, we're all (at least a bit) tired of spammy calls and emails. Enter the Information Regulator (IR), with a...

  • CIPC’s breach: don’t get caught catnapping

    WHAT’S HAPPENING AT CIPC? If you’re a business-y person living in South Africa, you’ve probably heard about this. For those of you not clued up, there was a recent cybersecurity breach...

  • Can we find balance in AI and privacy governance?

    THE AI GOVERNANCE AWAKENS We’ve written about the synergies between AI governance and privacy, but things are changing faster than Han Solo can make the Kessel Run. In October 2023, the...

  • Ever wonder how Elizabeth became a plain language lawyer? It’s utterly random.

    I always marvel at how utterly random life is. Here is the answer to the question ‘How did you become a plain language lawyer?’ The utter randomness 🎈My father is a lexicographer...

  • Library of old stuff

    Nothing new under the sun (and legal design is no different)

    If you think legal design and human-centred law is a modern innovation, think again. In his keynote opening at the Legal Design Summit in Helsinki, Marco Imperiale took us back to the...

  • Llama ponders the risks of AI and privacy regulation

    When AI and privacy governance collide

    Lately, you can’t swing a cat without hitting an article or post about AI (especially those posts where someone asked ChatGPT to write a letter/poem/limerick in the style of x). Snooze fest,...

  • Billables & Burnout

    Most legal businesses still run on the billable-hour business model. Here are five reasons why this approach has passed its sell-by date. 1. TAKING CARE OF YOUR ASSETS There are many ways...

  • Making the case for legal design

    You know when you’ve been merrily doing a particular thing for years and then an influencer gives it a new name, brings it into popular consciousness and suddenly it’s trendy? (Not wearing...

  • The Rehabilitated Lawyer: Join us online!

    Are you a sad lawyer? Hello, hi. *Hug* You’re not alone. The statistics are staggering: lawyers are 3.6 times more likely to be depressed compared to people in other jobs, while the...

  • Read: White paper on the impact of POPIA on cookies, advertising, marketing and privacy (with some cats thrown in)

    While we were creating our white paper on cookies, adtech, martech and privacy, we became obsessed with cats. Why did we take things so far? (Cat scrotums are pretty far.) Because writing...

  • Alright stop – POPIA time!

    Okay, maybe it’s not MC-Hammer-pants-level exciting, but we’ll be damned if we aren’t going to make it fun! If you feel like you need a refresher – or perhaps a fresh perspective?...

  • Marketers vs Lawyers: Why can’t we all just get along?

    Ever seen a toddler on one of those child leashes? They’re straining as hard as their little sausage legs allow, desperate to run free, talk to strangers and create a crayon masterpiece...

  • #Funlaw Challenge: 30 Posts in 30 Days

    There’s a lot of clutter online. We know. We’re as addicted to the infinite scroll as you are. But instead of being passive observers, Novation decided to take on the challenge to contribute...

  • Much ado about f*ckall

    Warning: the following article contains explicit language. That should be fairly apparent by the title but we’re legally obliged (we think) to put it into plain language. If you’re easily offended or don’t...

  • The science behind what makes things funny

    How to be funny AF

    Okay, we fibbed. While we will be sharing the theories of how jokes work, we can’t actually promise to teach you to be funny. Because, despite the hypotheses, philosophies, rules and formulas,...

  • Overthinking the Protection of Personal Information Act_Novation_Book

    Introducing… The Last POPIA Book You Will Ever Need

    There is no better way to introduce our book, Over-Thinking the Protection of Personal Information Act: The Last POPIA Book You Will Ever Need, than by reciting the Dunning-Kruger* prayer: ‘Let me...

  • 5 things information officers and octopuses have in common

    The octopus has become something of a theme here at Novation since we put one on the cover of our new POPIA book. This got us thinking about how information officers (IOs)...

  • Why it's okay to be funny about serious things

    Why it’s okay to be funny about serious things

    “Humour is a superpower in business, now more than ever,” says Naomi Bagdonas, a lecturer at the Stanford Graduate School of Business in her class on the benefits of leading with laughter....

  • Will POPIA kill direct marketing? Let’s bust the myths right now.

    Info Wars Episode IX: The Information Regulator Strikes Back

    The Information Regulator’s doomsday clock hit 0, life as we knew it changed. 1 July 2021 finally came. The re-consent pigeons were sent out and organisations joined in the communications assault with...

  • Do you need a POPIA crash course (or something a little stronger)?

    30 June 2021. Unless this is your birthday, this date probably fills most of you with some trepidation. No need – let’s turn the anxiety into excitement that POPIA is finally here...

  • How to write contracts that actually work

    For a long time, users of legal services have been getting the short end of the stick, from incomprehensible contracts and confusing court procedures to the way law firms bill for their...

  • Not another POPIA white paper: 10 years, 10 lessons

    It has been a decade since talk of the Protection of Personal Information Act started. Ten. Years. And finally we have an effective date. It is 1 July 2020. That’s right; it...

  • How to start your POPIA compliance project during lockdown

    It’s week 5 000 of the national lockdown, so we reckon everyone will appreciate a change of focus (since we can’t change the scenery). From what we can tell, most people’s pace during...

  • Are you mature enough for POPIA?

    Many of our projects begin with a similar story from new clients, ‘We made our first attempt to become POPIA compliant in 2015, but nothing changed. We asked ABC to help us...

  • Life or privacy: do we really have to choose? A reading list.

    My recent talk at the IAPP CapeTown/Johannesburg KnowledgeNet was around privacy, ethics and trust in the time of COVID-19. Here is some additional reading. 1. I feel like I am stuck in a...

  • It’s time to put on your own oxygen mask

    We all know the announcement at the beginning of a flight (remember those?): ‘In the event of a loss of cabin pressure, an oxygen mask will automatically drop from the ceiling. To start...

  • POPIA is coming, look busy.

    Why the face? The Information Regulator asked the President to announce 1 April 2020 as the commencement date for the Protection of Personal Information Act (POPIA). 1 April is also an auspicious date...

  • Write policies that matter

    We *heart* policies. Done well they can increase efficiency, improve teamwork, establish culture and protect everybody. Check out how we approach policies. Disclaimer: these slides are not for box tickers. And no, we...

  • Does data minimisation spark joy?

    The minimality requirement The requirement of minimality is one of the conditions for processing personal information in the Protection of Personal Information Act (POPIA). The POPIA provides that personal information can only be...

  • Hacks, leaks and breaches: the critical need for data privacy and regulation

    Elizabeth sat down with Red And Yellow Creative School of Business to chat about all things POPI vs GDPR and data privacy in the South African context. Fortunately for us, they caught it...

  • Hacking data breaches: We need a new breed of compliance officer

    R58.4 million. This is the average cost of a data breach today according to IBM. It is no surprise then that cyber resilience is top of mind for CEOs the world over. But...

  • Why your legal and compliance teams need a #complianoscopy

    Hardly a day goes by that clients don’t ask for recommendations on what new legal or regulatory technology to get to help their in-house legal or compliance teams perform better. The frequency of...

  • Super nerd_direct marketing form 4

    Direct marketing and the dreaded consent

    Everywhere we go, we are asked the same questions. Do we really have to use the terrible, horrible, no good, very bad form 4, to get consent for direct marketing when the POPIA comes...

  • Celebrate International Data Privacy Day with us!

    As we celebrate International Data Privacy Day, we think back on 2018. We spent a lot of time dealing with a deluge of questions from companies wondering whether they need to comply...

  • CHEERS TO 2018, BRING ON 2019!

    Well, 2018 was one crazy year. Data breaches, dramatic court hearings, lethal deli meats, controversial statements by a leader with freakishly small hands… and that was just at Novation. But seriously, the past...

  • A lawyer, a communication specialist and a change manager walk into a bar…

    You know what they say about all work and no play… At Novation we spend an above average amount of time talking, reading, watching series, cycling, drinking wine and playing Lego. We just...

  • HAVE YOU HEARD? UPDATED POPIA REGS TABLED AT PARLIAMENT

    Finally! The latest version of the POPIA Regulations have been tabled at Parliament. We have all been waiting anxiously for an update to the dreaded Form 4. Here is a reminder of what...

  • Ethics and data protection in AI

    When it comes to artificial intelligence (AI) it’s not difficult to see that we find ourselves in a time of great significance. Not only has AI magnificent potential, it is also progressing at...

  • Why, and what now Europe?

    If you’re in the digital or data driven services industry you most probably received  calls from a lot of panicky clients asking whether your service is GDPR compliant. Luckily for many South African...

  • The C-word

    Here at Novcon using the word ‘consent’ is pretty much like telling us you do not like our Lego ... yes, we take offence! So, we have dubbed consent the c-word, mostly because...

  • Heard around the office: POPIA compliance framework

    Hey Plain Jane is working with us on a tool to help people draft POPIA compliance frameworks. Things got a bit strange, even for us. Luckily, we caught Liezl on video. (With apologies...

  • Compliance & Legal consultant

    Novation Consulting is bursting at the seams with work. We need a top performing, creative mind, who knows compliance, risk management, and legal stuff. This is an opportunity to escape the chains of...

  • GDPR and POPIA – what you need to know

    Boo-Yah! owner Carmen Murray with guest Elizabeth de Stadler : Plain language and privacy law expert - GDPR and POPIA - what you need to know.

  • Dropped ice -cream

    Crying over spilled data. Greenwich University and the GDPR.

    The University of Greenwich in the United Kingdom was recently fined £120 000 by their Information Regulator, the Information Commissioner’s Office. You can read the full decision here. Why do we care? We...

  • Employee policies

    Employee policies: help your employees play well with others

    We often joke that when we start working on a specific kind of document for one client, several other want the same thing at the same time. It’s a strange, but happy coincidence...

  • Deleting your Facebook account

    Why I deleted my Facebook account

    For many years I have had significant misgivings about Facebook’s approach to protecting personal information. Despite this I kept a Facebook account as a means for my friends to update me on what...

  • Odd bird ostrich

    POPIA compliance and Codes of Conduct

    In a sense, the POPIA is a bit of an odd bird. In South Africa, we are used to rules-based legislation. Legislation that prohibits things, sets requirements, tells us what to do. This...

  • A bunch of our favourite (free) EU GDPR reads

    With the 25 May 2018 implimentation date for the EU GDPR creeping closer, there is a lot of information flying around. So much, that it is easy to feel overwhelmed. So we thought...

  • Sick of spammers? Know your rights.

    In this country, it’s hard to find something that everyone can agree on, but we’re fairly certain that we all agree that random ‘investment opportunity’ emails, cold calls from insurance companies and personal...

  • Your right to privacy. How will it change under POPIA?

    The Protection of Personal Information Act (POPIA) is set to kick in in the first half of 2018, according to the Information Regulator. Businesses have been scrambling to get their information governance practices...

  • 4 things you can do today to protect your privacy

    Privacy seems to be on everyone’s minds lately. Between online shopping, sharing your life on social media, and signing up for a webinar, it’s hard to keep track of where you’re sharing your...

  • Be smart about sharing your information

    28 January is Data Privacy Day, an international day created to raise awareness and promote privacy and data protection. When you think of a data breach you often think of twelve-year-old hackers recruited...

  • Drafting policies that are read

    Are your lawyers still not writing in plain language?

    Nearly a decade into having some of the best plain language legislation in the world, why are we not seeing more comprehensible contracts? Why aren't we seeing more of an effort from companies...

  • Dinosaur in a shirt

    What we’re up to: Plain Language Policies

    Over the last few months we’ve increasingly been working on redrafting all different types of policies for various different clients. From HR policies to information governance policies. It may seem like a tedious...

  • Guide dog

    Plain language privacy notices: Win your customers' trust

    Using plain language when you talk about privacy and personal information is key if you want to win your customers' trust. We have written about the POPIA requirement that a business must have...

  • Lost cat poster

    Better forms build better relationships and better data

    Good form design can change everything! Many consumer contracts reach consumers as part of an application form. While most attorneys will not consider the form as part of the contract, it often is....

  • photo of locks

    Access denied. When may you refuse someone access to their PI?

    Did you know that people may ask you to delete the personal information you have about them? The Protection of Personal Information Act (POPI) gives the data subject (a person or company) the right...

  • Privacy Shield protects information

    Survivor: Privacy Shield

    The first annual review of the functioning of the Privacy Shield was concluded and the report was published on October 18, 2017. What did it cover? The review covered all aspects of the...

  • How to deal with a data breach in your business

    The media is buzzing about the biggest data breach in SA. As these developments have shown, data breach can have a severe impact on your ability to do business, and it can tank...

  • Mind the gap

    SA’s largest data breach & how you can protect your data

    It turns out SA’s largest recorded data breach was traced to a Web server registered to a real estate company based in Pretoria, Jigsaw Holdings. They are a holding company for several real...

  • Start working on those operator contracts

    Get the right operator contracts in place in 6 simple steps

    In week 6 of our POPI DIY programme we look at what an operator is, and how to make sure you have the right operator contracts in place with yours. In terms of...

  • The 5 key elements of a BYOD policy

    A ‘Bring Your Own Device’ policy (BYOD Policy) is essentially a set of rules applicable to employees who want to use their personal devices for work purposes. No policy is a one-size-fits-all, so...

  • Cybercrime and Cybersecurity Bill

    Unpacking the Cybercrime and Cybersecurity Bill  

    South Africa has drafted (and redrafted) the Cybercrime and Cybersecurity Bill. The Justice Portfolio Committee held hearings on this Bill last week, and I was there. If you’re interested in what the Bill...

  • London Bus

    UK Data Protection Bill introduced 

    We unpack the new UK Data Protection Bill and how it relates to GDPR. On 13 September 2017, the UK Government introduced the new Data Protection Bill (the Bill) in the House of...

  • Nightmare on direct marketing street

      The long awaited POPI regulations are here. They don't say much, but what they do say spells disaster for direct marketers. And you know us, we are not alarmist. Section 69 of...

  • Hot off the press: POPI Regulations out for comment

    The draft POPI regulations have just come out for comment. We will be digesting them over the weekend and will let you know what is what on Monday on our blog. Weekend reading....

  • Clarity and risk mitigation

    Can plain language mitigate risk?

    We’re often asked whether a plain language contract will hold up in court. Whether we’re absolutely certain that, if a consumer is so dissatisfied with a product or service that he or she...

  • 6 Steps to build your Business Continuity Program (BCP)

    I might be slightly obsessed with Billions, the series. It is riddled with quotable quotes. My personal favourite? “It’s like Highlander: there can be only one” - Bobby Axelrod. Despite my inherent dislike...

  • Going up in smoke

    3 Things that will torpedo risk management

    All businesses have risks. Ideally, a business would mitigate all the risks, but this simply isn’t practical – you have to prioritise. At a high level risk management is intended to: * Identify...

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  • Your strong P@ssW0Rd may not be as unhackable as you think

    If you’re like me, you’ve spent at least a little time worrying about the security of your data. About someone hacking your bank account, or Facebook! And we’ve been taught that the best...

  • Does complying with the security requirement in POPI make you WannaCry?

    I often get asked what ‘appropriate security’ is for a particular business. Although this is a really important question, it is equally important that you ask the right person. The best way to...

  • State of the Privacy Shield

    The EU-US Privacy Shield is a data transfer framework which provides for the transfer of personal data of EU citizens to the US for processing without the risk of breaching fundamental European privacy...

  • Employment 101

    When we start a new business, putting employment processes and practices in place and ensuring labour compliance is, understandably so, not one of our biggest priorities. Let’s be honest, there are so much...

  • How a POPI project can mitigate the risks of a ransomware attack

    The recent WannaCry attack was one of the first highly publicised attacks in which ransomware was weaponized and used against numerous companies at once. It has caused many businesses to wake up to...

  • Protecting your Intellectual Property

    If you have a new business you often know – somewhere in the back of your mind – that you should be protecting your intellectual property (IP), but you tend to focus on...

  • Making online terms stick

    How often do you read the terms of use of the websites that you visit? If I could hazard a guess, I’d say hardly ever. Did you spend time and money on drafting...

  • Pawning (not pimping) your car

    It seems as though Allied Capital came up with (what seemed like) a clever scheme to avoid the National Credit Act. Essentially the idea was that a consumer would pawn their car to...

  • To and/or (and/)or not to and/or?

    As far as we are concerned, there is no question and it turns out that we are not alone in condemning the use of  'the bastard conjunction and/or'. As early as 1932 the American Bar...

  • Complain like a Boss: Some advice for consumers

    Have you been screwed over by a supplier? Here is what you do. #1: Don't hire a lawyer just yet Your first step should be to lay a formal complaint with the supplier...

  • Edcon found guilty of unlawful charges

    The National Consumer Tribunal has released a finding which - essentially - finds that Edcon has been unlawfully charging its customers a fee to belong to its club. This finding is very significant...

  • Save the Advertising Standards Association!

    There is no time to mince our words: The Advertising Standards Association will be liquidated by the end of April 2017 unless the advertising industry decides to bail it out. This was the...

  • Exclusions of liability: Don't make it worse than it has to be!

    Oh, the scourge of the fine print! How we wish we could get rid of it. But sometimes (not all that often), there are very real risks facing a business which, should they...

  • You have a data breach…now what?

    Data breaches are almost inevitable. So, in addition to working towards preventing data breaches, you should be asking yourself whether your business is ready to respond quickly and effectively when the pawpaw (or...

  • E-mail disclaimers: Are they worth the e-mail they are written on?

    Every day thousands of emails go out with email disclaimers. Some of the disclaimers are at the top, others at the bottom and still others contain a simple hyperlink which takes you to...

  • Processing child information: It doesn’t get more personal than that…

    Before we talk about the challenges of processing the personal information of minors, let’s take a step back. It feels like POPI has been in this kind of legislative limbo for years. Oh...

  • The importance of punctuation…

  • POPI or PawPaw? Who cares.

    So, the Information Regulator and the Department of Justice has asked everyone to stop calling the Protection of Personal Information Act 'POPI', but 'POPIA'. Of course, it only took about 5 seconds for...

  • Information Regulator says no…effective date this year

    So, the Information Regulator had a press conference today (13 February 2017). We were waiting with bated breath to hear what the effective date was going to be. Alas (or mercifully, depending on...

  • Direct email marketing around the world (well, almost)

    Looking for new clients? Don’t we all. Why not expand your client base to the US, Europe or India? Before you send out that gorgeous email campaign, let’s check the rules around marketing...

  • Our top five favourite privacy notices

    At Novcon we believe that organisations should have privacy notices that allow consumers to understand their privacy rights and to make informed decisions. We can achieve this by making sure that the wording,...

  • No-one knows when POPI is coming (but they sure like to pretend that they do)

    Hey you! The douchebag attorney/compliance specialist with the newsletter or event to peddle. Stop saying that POPI is coming into effect/commencing/whatever early in whatever year/quarter/month/week you happen to find yourself in. That is...

  • Our favourite lawyer jokes

    What is the difference between an accountant and a lawyer? Accountants know they're boring. How does a lawyer sleep? First he lies on one side, then he lies on the other. As the lawyer...

  • Rethinking privacy policies

    These days, I find it very difficult to see the point of overly legalistic privacy policies normally hidden behind a tiny link at the bottom of a webpage. Apart from the fact that I...

  • USA's long arm of the law just got cut off

    The United State's Court of Appeals for the Second Circuit has refused to re-hear the case between Microsoft and Department of Justice, effectively resulting in it being impossible for a United States court to issue...

  • What happens if you don't comply with POPI?

    Earlier this year Elizabeth wrote a useful article entitled ‘5 Reasons why POPI Compliance Matters’. While Elizabeth’s article addressed why POPI compliance matters, this article focusses on what happens if you don’t have POPI...

  • Privacy by design – getting it right from the start

    When do you have your best ideas? I have mine while on my bike, with the wind in my hair and dust (and often insects) in my mouth. This is when my mind...

  • Cybercrimes bill published

    An updated version of the Cybercrimes Bill has been published by the Department of Justice and Constitutional Development. This legislation aims to bridge the gap in South African legislation which has emerged as...

  • 5 reasons why POPIA compliance (blegh!) matters

    (and they have nothing to do with POPIA really) It has become clear in recent years that the proper treatment of their personal information matters to consumers (we have tested this), but why...

  • Cybersecurity Bill approved by Cabinet

    South Africa's cabinet has approved the Cybersecurity Bill. If the Bill becomes an Act there will be very definite changes to the legal landscape for all businesses - partly because the cybersecurity bill...

  • 10 reasons why e-learning is the way to go!

    We’ve all been there: the stuffy room with the uncomfortable seats, the monotonous drone of the facilitator reciting legislation – he’s somewhere in the middle of a 144-slide PowerPoint presentation and you’re somewhere...

  • From ??? to A-HA!!! Risk mitigation through training

    We love training. Why? Because, done right, training and awareness can mitigate risk and change behaviour for good. But compliance training has gotten a bad reputation. All too often employees associate compliance training...

  • Giving hope to the hopeless – helping over-indebted people reclaim their lives

    Paul recently published an article on the Esselaar Attorneys web site considering the plight of the over-indebted consumer who does not have enough funds to be declared insolvent. In essence - in an...

  • Icasa Regulations On Code Of Conduct For Premium Rated Services

    Ilze has written an article regarding the new regulations by ICASA for premium rates services that affect all Wireless Application Service Providers (WASPs for short). In essence ICASA is prescribing how premium rated...

  • How to calculate Minimum Expense Norms

    While an affordability assessment has always been part of the National Credit Act (NCA), recent amendments to the NCA Regulations have introduced a mandatory procedure for affordability assessments in the form of regulation...

  • Privacy implications of CIPC data

    Recently Companies House in the United Kingdom (the United Kingdom version of the Companies and Intellectual Property Commission (CIPC)) took the unusual step of deciding to provide online company information to the public...

  • Is this where the word 'spam' comes from?

    When did we start referring to unsolicited marketing messages as 'spam'? While researching my book, I found an article 'The regulation of unsolicited commercial communications (spam): Is the opt-out mechanism effective?' by Sebo...

  • Direct marketing: Opt-in or Opt-out??

    The introduction of the Protection of Personal Information Act (POPI) will provide direct marketers with more hurdles to clear. The introduction of the CPA gave direct marketers much food for thought. The most...

  • POPI Online training Programme now available

    We have developed an online training programme for employees on the Protection of Personal Information Bill. This is a project with Compliance Online. Go have a peek: www.complianceonline.co.za. The programme comes with extensive reporting functions...

  • Smart Contracts – the end of the traditional paper contract?

    Over the last few months I’ve come across the term ‘smart contracts’ enough times to make me sit up and take notice. Some articles[1] have even mused that smart contracts may mean the...

  • The CPA and quality problems (cars as a case study)

    Since the enactment of the CPA, the question whether goods can still be sold ‘voetstoots’ or ‘as is’ has been a hotly debated topic. The short answer is that ‘voetstoots’ clauses as we...

  • Cancellation of fixed term agreements, once and for all

    One of the most common questions I get from consumers relates to whether suppliers can refuse to let them cancel fixed term agreements. In fact, it has happened to me a couple of...

  • Drowning in Red Tape: The new threshold for registration as a credit provider

    With all the pieces of legislation that are constantly being updated it is easy to miss changes to legislation that are really important – especially if that change comes in the form of...

  • Copyright and Originality: Preserve your Notes!

    Most people know that before you can prove an infringement of copyright, you need to prove that the material ('work') that you claim is subject to your copyright must be original enough (and...

  • Why Information Governance is more than protecting personal information

    As a rule we approach the protection of an organisation's information from four different angles. Rather than focussing on a strictly "legal compliance" perspective we try and gain some benefit for an organisation...

  • Standard Bank v Dlamini: A plain language coup in the Durban High Court

    The Durban High Court recently used plain language to provide an out to a consumer who concluded an agreement with Standard Bank. Whether one agrees with the judgment or not, this case is...

  • Explaining the grey listed terms in the Consumer Protection Act (regulation 44)

    Regulation 44 of the Consumer Protection Act 68 of 2008 contains a list of terms which are presumed to be unfair. A supplier is allowed to insert these terms. However, where the supplier...

  • In search of plain language

    Few of the provisions of the CPA have been more perplexing to attorneys than section 22, which deals with the plain language standard. Perhaps this is because, ironically, the section which explains what plain...