European Union – Data protection. As there were disagreements between the members of the court on whether s 32(4) of the Data Protection Act 1988 (DPA) complied with Directive (EC) 95/46, the Court of Appeal, Civil Division, held that there should be a reference to the Court of Justice of the European Union for a preliminary ruling on whether s 32(4) and (5) of the DPA contravened the Directive.