Penalty notice: considering whether to issue a penalty notice: considering any previous action taken
Before issuing a penalty it is important to consider the trader’s overall attitude to compliance and any history of non-compliance:
- if it is the first time a trader has encountered this process, then providing education may be more appropriate than taking CCP Action
- if we have already issued a warning letter about a broadly similar contravention within the last two years then we should issue a penalty
- if we have previously issued a letter of written instruction for a broadly similar contravention and advised the trader of the corrective steps they needed to take to improve compliance and they failed to take this action we should issue a penalty
- if we have already issued a penalty about a broadly similar contravention within the last two years then we may consider a higher penalty for the further contravention.
Records of previous penalty action can found by checking the CCP spreadsheets.
You must include on the CPAC details of what action was taken previously to address the error.