That the words in the WW Act are "relevant consent" rather than "prior consent" may be the key to determining the issue....I spent a working lifetime dealing with Consumer Credit Acts... when even the simplest language was open to interpretation.
One enterprising chap, with his girlfriend, set up a company to "buy" consumer debts, not from the banks or loan companies, but from consumers themselves. They then went on a credit spending spree, racked up £100k of debt on , then "sold" their debts to the company for £1, which company failed of course to make any payment. The couple when sued asserted that they were fully entitled to sell their "obligation to pay". This confounded even the most hotshot of lawyers, until after some years it reached the Court of Appeal who shakily ruled that "obligation to pay" under the CCActs was only transferable by lenders. Very little in life is as certain as some on this thread believe.