19 minutes is way in excess of any consideration period so that argument won't fly. The "technical flaw" in that PoFA 9(2)(e)(i) has not been complied with, won't do you much good at initial or secondary appeal stages as ECP will not accept it and POPLA are too moronic to understand it. It would only be useful if it ever went all the way to a court hearing in the small claims track.
Nobody pays ECP and this is how I predict this will pan out...
Whatever appeal is made to ECP and then POPLA will be unsuccessful. You will then ignore all reminders and Debt Recovery Agent (DRA) letters. Eventually you will receive a Letter of Claim (LoC) issued by DCB Legal. Tell us when you get that.
After we provide the response to the LoC, you will receive an N1SDT Claim form from the CNBC. We will advise on how to respond and provide a defence and draft order.
Eventually, some time early next year, the claim will be discontinued and that will be the end of the matter. I am 99.9% confident of this. Others on here will tell you what is likely if you are the 0.1% of people that this is possibly not the case.
Whether you bother with an appeal, is up to you. In my experience, it is futile but it is up to you whether you bother. The outcome is more likely than not going to be what I have predicted above.