It is if you're asking someone to buy a new one.
There is no reason why they couldn’t carve out consent for a reminder from consent for marketing. It was an eye-opener seeing the different GDPR questions Holiday Inn in Hamburg asked compared to the generic nonsense here.
We have a real sickness in our political culture that every small matter must somehow be turned into a crime or a matter for the state.
I agree, but this isn’t a political culture, this is a commercial company exploiting the law to extract money from people by making ridiculous threats. The lack of willing to fix our broken legal system is a political culture, agreed.
I am constantly amazed at how many people asking for help on this forum are foreign students with limited English; assuming even just half of them are telling the truth, it suggests to me that the TOCs are deliberately targeting these people.
We see the same with Capita, who enforce the TV Tax. My experience at Citizens Advice was that 90% of people presenting with TV Tax fines were single mothers, which rather indicates Capita were deliberately targeting them.
It’s really not too difficult to take a bit of personal responsibility for our own finances and travel documents.
Of course the TOCs take no such responsibility when they mess up. There’s no £90 admin fee paid to someone who successfully appeals a Penalty Fare, or to someone who is wrongly denied travel because the barrier staff at the station don’t understand the ticket products they are inspecting.