Fundraising on private sites to which the public have “unfettered access”, such as railway stations or shopping centres, is essentially the same as street F2F in the way it is carried out. What differentiates it from street fundraising is how it is regulated and licensed. Putting aside the legal ambiguity surrounding the question of whether direct debit fundraising falls within the scope of the Police, Factories etc (Miscellaneous Provisions) Act 1916, because cash collections on private sites are not licensed, then direct debit collections certainly would not be. The Face-to-Face Activity Code of Fundraising Practice applies to private site F2F.