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NPA misrepresentation allegation: full rebuttal and conduct review | The Reasonable Adjustment

The NPA’s misrepresentation allegation, a full rebuttal and conduct review

Q: What is the current SAR position?

NPA SAR refused after being described as a backdoor disclosure. IPS SAR received late and incomplete by post. This article focuses on the NPA allegation and conduct.

Published 15 October 2025 By Kieron JH

This is the promised piece. The National Pharmacy Association (NPA), through solicitor Alicia Grace Day, alleged I misrepresented myself by using The Reasonable Adjustment brand. Here is the factual record, the legal test for misrepresentation and reserved activities, and the conduct concerns that follow.

No spin, just receipts and clear asks. Right to reply is open.

The short version

The allegation: NPA says I purported to be two different people, as an individual and as The Reasonable Adjustment. That is wrong on the facts. ^[1]^[2]
The record: Identity and disclaimers were consistent across every email, the TRA link is public. Advocacy is not deception.
The law: Misrepresentation needs a false statement of fact, intent to induce reliance, actual reliance, and loss. None of those elements are met.
The conduct problem: Attempts to corral all communications, to reset SAR deadlines, and to threaten harassment labels look like process games, not accountability. ^[3]^[4]
What we want: Withdraw the allegation, confirm written only contact, complete the NPA SAR from the original date with a privilege log if used, and fix privacy governance.

Rights are not favours

A right withheld is no right at all, it is a favour. And favours can be withdrawn. Rights, by definition, cannot. The moment an organisation treats rights as favours, it abandons law and slides into arbitrary power. That is not equality before the law, it is preference, and preference has no place in justice.

Section 20 of the Equality Act 2010 makes it plain, reasonable adjustments for disabled people are duties, not optional courtesies. Ms Day and the NPA did not answer this point. That silence is telling. Readers can decide for themselves once they have seen the evidence.

What NPA actually alleged

NPA’s solicitor framed the use of my brand as an attempt to appear as two different people. The suggestion is that emails from me and emails carrying The Reasonable Adjustment header are separate identities. Readers deserve clarity, so here it is, straight.

I write as Kieron JH. I also operate The Reasonable Adjustment, which is a public interest platform. The connection is disclosed everywhere.
Every message carried my signature and a disclaimer that I am not a solicitor. There was no claim to a protected title, and no reserved legal activity was performed.
Multiple counterparties addressed replies to me by name and to the platform in the same line. There was one person, one platform, fully disclosed.

Personal note on particulars

I have given NPA numerous clear chances to particularise this allegation. They have not. Instead, the goalposts moved and I was told my writing was now defamatory and harassing. If there was a real defamation claim here, the fastest path would be to set out the particulars, the exact words complained of, the meaning alleged, and the harm. The refusal to particularise speaks for itself.

For context, this was their response to several requests to particularise a very serious allegation, powered by vibes, not statute: NPA SAR refusal, noreply threats, network logs. Readers can review the record and decide. The evidence proves otherwise.

On the so-called “large volume of emails”

Ms Day complained that I sent a large volume of emails. The term is subjective. What some call large, others call diligent follow up. Every message I sent was in pursuit of lawful answers, not noise. Email places no obligation on an immediate or substantive reply. Recipients can read, prioritise, or delegate at their own pace.

However, when those emails concern the legal compliance of your own website, a prompt and professional response is not a favour, it is a duty. Slow walking or deflecting those questions only compounds the issue.

In plain terms, this was a low blow. NPA have not demonstrated control or confidence here. They have demonstrated something simpler, desperation.

The legal test, why the allegation fails

Misrepresentation has elements. Strip away the rhetoric and check the boxes.

False statement of fact: None identified. Using a transparent brand is not a false statement.
Intent to induce reliance: The purpose was transparency and accountability, not tricking anyone about who was writing.
Actual reliance: No decision maker was misled about identity, the correspondence history proves the opposite.
Loss flowing from reliance: None caused by identity confusion. Any alleged loss belongs to substantive issues, not to a brand header.

Reserved activities sit under the Legal Services Act 2007. I have not carried on any reserved legal activity for anyone else. Specifically, I have not conducted litigation on behalf of others; any litigation activity has been solely as a litigant in person in my own case. I have not exercised rights of audience beyond those available to a litigant in person. I have not held myself out as a solicitor or any other authorised person. I write, ask questions, request data, and publish matters of public interest. That is lawful. Bruising egos and humbling professionals is not unlawful. It is, however, a principle of this platform.

Conduct concerns that matter

Gatekeeping and process gaming

Communications corralled: NPA Insurance positioned itself as the only route for contact, then warned that contacting the trade body may be treated as harassment. That chills legitimate scrutiny. ^[3]^[4]
SAR clock reset attempt: A scope clarification was treated as a new request to push deadlines. That reads like deadline drift. ^[5]^[6]
Goalposts moved to defamation and harassment: after repeated chances to particularise the misrepresentation claim, NPA pivoted to saying my reporting was defamatory and harassing, without identifying the words complained of, the meaning alleged, or any serious harm. If defamation was real here, particulars would be the easiest thing to provide. ^[7]^[8]
Privilege black box: Broad privilege claims were asserted without a log. If privilege is relied on, a basic log should exist. ^[9]

There is also a disability context. A written only adjustment was on record. Termination decisions should be communicated in writing to the person affected. In this case, key communications were routed through a clinic and service withdrawal was pushed via that route. That does not meet the spirit of equal access. ^[16]

Why NPA credibility is already a problem

This article is about the misrepresentation allegation. The points below relate to the NPA’s own correspondence and decisions, not the supplier.

Refused to particularise the allegation after multiple opportunities.
Reframed reasonable correspondence as harassment instead of answering specifics.
Tried to reset subject access request timelines after a scope clarification.
Refused my subject access request, calling it a backdoor disclosure, without setting out a clear legal basis.
Outstanding privacy governance issues were flagged and not substantively addressed.

The supporting documents are listed in the Evidence links section below. Readers can cross check every claim there.

What good faith looks like from here

Withdraw the misrepresentation allegation in writing, or provide particulars with dates and quotes that can be checked. ^[11]
Confirm written only contact across all teams, then produce the written cessation notice or confirm none was sent. ^[12]
Hold all relevant data, email, CRM, call logs, and internal chats, and confirm preservation in writing. ^[13]
NPA: Complete the SAR from the original date and provide a simple privilege log if privilege is used. ^[14]
IPS: Publish a current privacy notice with version history, explicit legal bases, cookie controls that block non essential cookies until opt in, retention ranges, and an accountable owner. ^[15]

Frequently asked questions

What is the NPA misrepresentation allegation about?

The National Pharmacy Association alleged I misrepresented myself by using The Reasonable Adjustment brand. This article sets out the evidence record and legal analysis that rebuts the allegation.

Did this involve any reserved legal activities?

No. I did not conduct litigation for others or claim any protected title. I acted only as a litigant in person in my own matter and as a journalist and advocate.

What is the current SAR position?

NPA SAR: refused after being described as a backdoor disclosure. I asked for the legal basis and for particulars. The position shifted and the request was declined without the requested particulars. That is the outstanding SAR addressed in this article.

IPS SAR: received by post several days after the deadline that NPA tried to reset. The bundle was two to three pages and omitted most of the scope, especially internal correspondence. This is noted for completeness. The focus here is the NPA allegation and conduct.

Evidence links

Publication note: The correspondence and email addresses referenced here were sent by the NPA from contact addresses they publish on their own website, and the PDFs are hosted on this site for verification. Redactions have not been applied to sender addresses, for authenticity and because the addresses are already publicly available. This is a public interest report.

NPA correspondence for this article

Context: supplier chronology

Notes on method and corrections

Author: Kieron JH. Role: publisher of The Reasonable Adjustment.

Method: all claims are footnoted to primary documents. Email addresses shown are those the NPA publishes on its own website. PDFs and images are hosted here for authenticity.

Corrections: factual corrections with evidence will be applied promptly and noted in the version history.

Right to reply

NPA and IPS are invited to respond with evidence. Corrections will be published promptly with equal prominence. Send replies to [email protected]. If you believe any fact here is wrong, quote the line, give the counter evidence, and state your source. Simple.

This page will be updated if new documents arrive. Version 1, 15 October 2025.

Scope and SAR clarification

This article addresses the NPA misrepresentation allegation and related conduct. The outstanding SAR at issue here is the NPA SAR. It was refused after Ms Day described it as a backdoor disclosure and did not particularise the legal basis for refusal when asked to do so.

For completeness, IPS Pharma and Vertical Pharma Resources sent a small SAR bundle by post several days after the deadline that NPA attempted to reset. It was two to three pages and omitted most of the scope, especially internal correspondence. That record is noted. The main subject of this article is not IPS. The focus remains on the NPA allegation and conduct.

For the separate write up on the NPA SAR refusal with correspondence and network logs, see NPA SAR refusal, noreply threats, network logs.

Truth vs Vibes: The NPA’s Misrepresentation Claim