Appendix 3 - The Government
Introduction
1.1 This document sets out the Government's response
to the Fifth Report of the Culture, Media and Sport Select Committee,
on Privacy and Media Intrusion (HC 458-1), published on 16 June
2003.
1.2 As the Committee recognises in the introduction
to its report, there is a difficult tension between the need to
preserve free speech in an open and democratic society, and the
important need to protect individuals from unwarranted intrusion
by the media into their privacy. Even when there is sufficient
public interest to justify media activity, it can be difficult
to ensure that the extent of that activity is proportionate.
1.3 The Government strongly believes that a free
press is vital to the health of our democracy. There should be
no laws that specifically seek to restrict that freedom, and Government
should not seek to intervene in any way in what a newspaper or
magazine chooses to publish. We therefore support self-regulation.
However, in her evidence to the Committee, the Secretary of State
made clear her desire to see the current system improved. She
raised the following questions for the PCC to answer:
- Should the PCC be more "pro-active"
in its approach?
- Would the PCC consider independent
scrutiny of its procedures?
- Is there a need to make the
appointments process more transparent?
- Is the balance of lay members
and industry members right?
- What scope is there for the
PCC to raise its profile and become more accessible to the public?
- Is there a case for devising
an appeals mechanism that is not only independent of the Government
but also seen to be free of undue industry control?
- Should the PCC make greater
use of hearings?
We are glad that Christopher Meyer has indicated
his intention to look at most of these ideas, and we welcome the
Committee's report which has taken the debate on a stage.
1.4 The central recommendations in the Committee's
report relate mainly to improvements to the system of self-regulation,
but the Committee also make the case for introducing a privacy
law. The Government does not accept that case, and considers that
existing legislation is capable of dealing adequately with questions
of privacy. A detailed response on this point is at section 2.
Sections 3 and 4 contain our responses to the Committee's other
recommendations.
A new privacy law?
2.1 The Committee's conclusion - and recommendation
- on this issue is:
2.2 On balance we firmly recommend that the Government
reconsider its position and bring forward legislative proposals
to clarify the protection that individuals can expect from unwarranted
intrusion by anyone - not the press alone - into their private
lives. This is necessary fully to satisfy the obligations upon
the UK under the European Convention of Human Rights.There should
be full and wide consultation but in the end Parliament should
be allowed to undertake its proper legislative role. (Paragraph
111)
2.3 The debate over whether to introduce specific
privacy legislation is a legitimate one. There are several reasons,
however, why we believe more legislation is not only unnecessary
but undesirable. We need to ask what would be the purpose and
benefits of such legislation. First of all, various aspects of
privacy are already protected by legislation - for example, the
Data Protection Act - and there is the over-arching impact of
the 1998 Human Rights Act's (HRA) provisions on the right to respect
for private life. However, Section 12 of the HRA makes provision
for substantial protection for the historic right to free speech,
and there is a balance to be struck between freedom of expression
and the right to privacy. We believe that that balance is not
always to be found at the same point because, in effect, some
people can be said to have invaded their own privacy by, for example,
granting access to photographers, and thereby making public details
of their private lives. The weighing of competing rights in individual
cases is the quintessential task of the courts, not of Government,
or Parliament. Parliament should only intervene if there are signs
that the courts are systematically striking the wrong balance;
we believe there are no such signs.
2.4 One possible approach might be to introduce legislation
that simply banned the invasion of privacy unless it is warranted
by the public interest. But it is exactly on this basis that the
Code of Standards overseen by the PCC works. We have no doubt
that there are occasions where an invasion of privacy is warranted
because it is in the public interest; it might, for example, lead
to the unveiling of a crime. Because there are two conflicting
rights involved, disputes require resolution on a case by case
basis, and we believe that it is entirely appropriate for the
courts to decide where the right balance lies, rather than setting
out boundaries in legislation that attempt to cover all events.
2.5 Privacy legislation would pose a particular problem
for those not normally in the public eye because the mere fact
of seeking a remedy in the courts can, of itself, lead to a further
loss of privacy. The provision of an effective, informal remedy
through self-regulation can protect against the exacerbation of
any harm. People in public life are also entitled to a private
life, but it is for the courts to determine the extent, in each
individual case, to which a person has consented to the infringement
of their privacy through their engagement in public life. There
is not one rule for celebrities and another for members of the
public; the rule is the same, but the current situation allows
individual circumstances to be taken into account.
2.6 The press should not simply be able to abdicate
responsibility for this issue to the courts. It is clear that
they do not do so, and the process of weighing the right to privacy
against the freedom of the press is incorporated into the industry's
Code of Practice. The Code includes a clause on privacy which
mirrors the HRA by stating that everyone is entitled to respect
for his or her private or family life. Intrusions can only be
justified where it is in the public interest. This means, for
instance, where "intrusion" exposes a crime, protects
public health or safety or prevents the public being misled. Sensibly
applied, these seem to us to be perfectly justifiable exemptions,
and we believe that the focus should be on ensuring that the press
are meeting their responsibilities under the terms of the Code.
The broadcasters
3.1 Ofcom must seize the opportunity presented
by its new structure to undertake a thorough review, including
wide consultation, of how complaints against the broadcasters
should be tackled and on the substance of a new code upon which
the system will rest. In the meantime, and under the new arrangements,
we recommend the continuation of hearings for complex cases (but
we see no good reason why the complainant cannot make a full record
of the proceedings). (Paragraph 36)
3.2 Section 107 of the Broadcasting Act 1996 sets
out the requirement for the Broadcasting Standards Commission
(BSC) to publish from time to time a code giving guidance as to
the principles to be observed by broadcasters in avoiding unwarranted
infringements of privacy. The BSC is also under a duty to review
the code and before doing so to consult such persons as appear
to the BSC to be appropriate. Under the Communications Act 2003,
Ofcom will assume responsibility for this code and for the related
duties.
3.3 Although Ofcom will inherit the current BSC code,
they will need to review and consult on their own code, in the
light of their own duties and functions set out in the Act: the
kind of thorough consultation and review process recommended by
the Select Committee will therefore need to be undertaken by the
regulator. The Government considers that it is best left to Ofcom
to decide when such a review should take place.
3.4 Sections 110 and 111 of the Broadcasting Act
1996 set out the procedures that must be followed by Ofcom in
considering complaints about unwarranted infringements of privacy.
However, there is nothing to prevent Ofcom from establishing supplementary
procedures. The Government is sure that both common sense and
the statutory duties laid on Ofcom to follow good regulatory practice
would lead them to conclude that they should both publish, in
simple form, guidance on their procedures for tackling complaints,
and review such procedures from time to time. However, the Government
also believes that it is best left to Ofcom to determine when
and precisely how to do so.
3.5 As for complainants being able to make a full
record of the proceedings, this is not current BSC practice, but
it is not precluded by legislation. It will therefore be for Ofcom
to consider this procedural matter.
3.6 We were not at all convinced that door-stepping,
by a film crew, of people who have refused, sometimes in writing,
to be interviewed is really done to give the subjects of a programme
a final opportunity to put their side of the story. The motivation
is surely less judicial and more about entertaining footage. Such
intrusion, and broadcasting the result, should only be undertaken
in important cases of significant public interest. (Paragraph
37)
3.7 The Government recognises that the validity or
otherwise of "door-stepping" must be a judgement made
by the broadcasters and the broadcasting regulators. The BSC code
already addresses door-stepping and the limited circumstances
in which it might be acceptable and further guidance is set out
in the ITC Programme Code and BBC Producers' Guidelines: the latter
make clear that "door-stepping should not be used merely
to add drama to a factual report". Broadcasters must comply
with the codes and guidance and there must be an effective regulatory
regime to ensure compliance. We believe that the Communications
Act provides for that.
3.8 The BBC should respond to the preference of
individuals for their privacy complaints to be dealt with by an
external body (previously the Broadcasting Standards Commission)
and should either increase the demonstrable independence of its
own system or refer complaints to Ofcom if the initial response
from the programme-makers does not resolve the situation. The
BBC should participate fully in the Ofcom review that we recommend
above. (Paragraph 38)
3.9 Ofcom is required to consult the BBC on their
review of their code and the BBC has given a commitment to work
closely with Ofcom. It will be for Ofcom to ensure that the public
are fully informed of their rights to complain to Ofcom themselves
about unwarranted infringements of their privacy, although we
think it quite right that broadcasters themselves should seek
to resolve complaints if they can.
3.10 Ofcom and all the broadcasters should engage
with the PCC and the press industry to develop ways of tackling
the media scrums that still seem to gather at the scent of a story.
Described by Lord Wakeham as "a form of collective harassment"
this is a matter that must be capable of being sorted out - especially
when it is the victims of violent events, or their families, that
are involved. (Paragraph 39)
3.11 The Government welcomes this recommendation.
Media scrums are more to do with intimidation and potential unfairness
than with privacy, and the issue is addressed in the guidance
offered to broadcasters in the BBC Producers' Guidelines and ITC
Programme Code. We believe that Ofcom, the broadcasters, the PCC
and the press industry are capable of determining the nature of
their inter-relationship with regard to "media scrums",
which engage the interests of the regulators and self-regulators
of different media.
3.12 We agree with the Committee that this is a matter
in which closer co-operation between the regulators of the different
media would be in the public interest. We also consider that each
has sufficient scope to allow them to research the precise nature
of the effect that the broadcast and press media together have
on individual news stories, and to take any action necessary to
reduce any negative effects.
3.13 Of necessity we reserve our judgement on
the precise arrangements to be established by Ofcom. This is a
matter to which we may well return. (Paragraph 40)
3.14 The Government notes the Committee's comments.
The press
4.1 Most of the Committee's recommendations on the
press address ways in which the PCC might consider changing the
way it operates. The Secretary of State for Culture, Media and
Sport made it clear in her evidence to the Committee that any
such suggestions were for the PCC to consider and that, ultimately,
it was for the PCC alone to determine whether - and how - to take
forward these suggestions and recommendations. Our comments on
the recommendations therefore need to be read with that over-arching
qualification in mind. We have commented on the Select Committee's
recommendations in the order in which they were listed.
4.2 Notwithstanding the PCC's avowed intent to
secure resolution between parties to a complaint, if possible,
we recommend that the PCC consider establishing a twin-track procedure.
The new provision would be to respond to those complainants who
did not want mediation but wanted the Commission to make a judgement
in reference to the Code on their case (after the normal exchange
of papers) without this insistence prejudicing the result. At
the very least the Commission should make an assessment amongst
complainants as to the level of demand for such an innovation.
(Paragraph 61)
4.3 It is hard to see what would be gained from the
introduction of such a system. It is open to complainants to refuse
attempts at finding a resolution if, for example, they believe
that an apology or correction offered is inadequate in some way.
But newspapers could not, in any case, be prevented from offering
to make amends if they thought it was justified when a complaint
was brought to their attention. Nonetheless, there would be no
harm in taking public soundings on the idea.
4.4 There are a number of issues that arise in
advance of the publication of a story that do not amount to "prior
restraint" or "press censorship". We believe that
the PCC should consider establishing a dedicated pre-publication
team to handle inquiries about these issues from the public and
liaison with the relevant editor on the matters raised. This team
should also handle issues related to media harassment, including
the production and promotion of guidance to both press and the
public, liaison with the broadcasters and the transmission of
"desist messages" from those who do not want to talk
to the media. The first job for the prepublication team should
be the collaborative work with Ofcom on "media scrums"
that we recommend above. (Paragraph 62)
4.5 We believe it should be recognised that, although
the PCC does not have a specific "prepublication" team,
it already carries out many of the functions the Committee has
suggested here. For instance, the Committee heard from editors
that they can call the PCC for advice if they have doubts over
a particular article. It is, of course, more difficult for members
of the public to discuss an article at the pre-publication stage,
quite simply because they do not normally know what will be published.
The PCC also already provides advice and a help-line for those
who feel that they are subject to harassment. The PCC have done
some good work in raising their own profile but it is true that
many people are not aware of the full range of their work until
it is too late. On occasion - where it has been necessary - the
Commission has issued a "desist message". The Committee
heard that this happened during the coverage of the events in
Soham last year. There can be no doubt that the newspapers had
a legitimate right - indeed a duty - to report on those events,
but a point was reached when there was nothing further to be gained
from their presence in the town.
4.6 Regardless of whether there is a specific team
at the PCC to deal with these issues, we would like to see the
emphasis on encouraging the press itself to take responsibility
for adherence to the Code rather than using the PCC to police
a Code which the press are believed to be trying to get around,
or as nanny to a press seen as incapable of adhering to a Code
of Practice.
4.7 We recommend that the Code Committee, Pressbof
and the Commission consider the following in relation to the Code
of Conduct.
i) The Code's ban on intercepting telephone calls
should be updated to reflect the communications revolution (in
line with the provisions of the Regulation of Investigatory Powers
Act 2000) and should include reference to the privacy of people's
correspondence by e-mail and between mobile devices other than
telephones.
ii) An additional element of the Code should be
that journalists are enabled to refuse an assignment on the grounds
that it breaches the Code and, if necessary, refer the matter
to the Commission without prejudice.
iii) The Code should explicitly ban payments to
the police for information and there should be a ban on the use
and payment of intermediaries, such as private detectives, to
extract or otherwise obtain private information about individuals
from public and private sources, again especially the police.
(Paragraph 63)
4.8 We would agree with the Committee that if there
is a clause banning the interception of telephone calls, it seems
reasonable that it should also reflect other more modern methods
of communication. This recommendation and that contained in paragraph
63iii do, however, raise the wider question of how the Code should
respond where issues are also covered by the law. For instance,
it is possible to imagine circumstances where a journalist could
obtain vital information on a story by breaking into a property.
Regardless of the story - and even if in journalistic terms it
might, ultimately, be in the public interest - this hypothetical
course of action would of course be against the law. The same
is true, for example, of the provisions in the Regulation of Investigatory
Powers Act 2000, which makes it an offence to intercept a telephone
call or other communication without lawful authority. Yet while
the one offence is covered by the Code, the other is not. In our
view, there needs to be wider consideration of whether it is right,
or necessary, for the Code to duplicate the law in some circumstances,
and, if so, what those circumstances are. We deal specifically
with the matter of payments to police officers at sections 4.35
to 4.40 below; but, briefly, there are laws which make this illegal
for the police officer and for the person offering payment for
information.
4.9 The Committee heard evidence that more and more
journalists, as well as editors, had
adherence to the Code written into their contracts.
We welcome this development and believe that this is a positive
way to address, at least to some extent, the issues raised in
the Committee's recommendation at 63ii.
4.10 We welcome the assurance of the Chairman
of the PCC that the selection of candidates for the role of lay
commissioner would be put on a proper, open and transparent footing
from now on. We note his undertaking to have a further lay commissioner,
appointed under such arrangements, in place before the end of
2003. (Paragraph 64)
4.11 We believe that the Commission would command
more confidence in the independence of its membership if it adopted
the following proposals:
i) Lay members should be sought and appointed
for fixed terms under open procedures including advertisement
and competition.
ii) Press members should be appointed for fixed
terms from across the industry. There should be an explicit presumption
that they are not there to represent the interests of their associations
but to offer the benefits of their particular experience whilst
acting independently as members of a quasi-judicial body.
iii) Press members (and here we include members
of the Code Committee) who preside over persistently offending
publications should be required to stand down and should be ineligible
for reappointment for a period - perhaps the length of a term
of office. Persistence could be defined as "three strikes
and you're out".
iv) The lay majority should be increased by at
least one; as provided for in the PCC's Articles and accepted
by Sir Christopher Meyer, the new PCC Chairman.
v) The Appointments Commission should appoint
an independent figure, also under the new procedures, to implement
the procedural appeals process to which Sir Christopher Meyer
has referred. To this responsibility we would add the task of
commissioning a regular external audit of the PCC's processes
and practices - a version of accreditation. While the "standard"
would probably be unique to the PCC, the methodology has been
pretty well established throughout the corporate world.
vi) The Code Committee, which at the moment is
composed entirely of editors, should be re-established with a
significant minority of lay members. (Paragraph 67)
4.12 The Government would also welcome more transparent
recruitment for lay commissioners, and supports the proposed increase
in the lay membership. We believe that it would increase public
trust in the essential fairness of the system and, by extension,
of newspapers if the PCC and the process of self-regulation were
made more transparent.
4.13 We recommend that the PCC, under its new
Chairman, considers the case for taking on a more consistent approach
to foreseeable events that herald intense media activity and people
in grief and shock; and for acting as soon as possible after unexpected
disasters have occurred. This may be another appropriate responsibility
of the pre-publication team. (Paragraph 72)
4.14 One of the aims of the Code is to ensure a consistent
and appropriate approach across the spectrum of the print media.
The Code governs their behaviour whether they are reporting events
that generate intense interest, or more day-to-day events. By
their nature, high profile events will often involve people in
grief and shock but that does not necessarily mean that they do
not want to talk to journalists. Some people welcome the opportunity
to speak to the press even in the most difficult circumstances.
Others, of course, will not welcome a media presence. It must
be recognised that the public have a right to receive information,
and that it is the professional duty of journalists to provide
that information. It is in managing these conflicting demands
that difficulties arise. But the Code exists to provide guidelines
for journalists and editors in any circumstances, including the
most difficult; reminding them of their responsibilities under
the Code from time to time is no bad thing and, on occasion, specific
advice will be appropriate. This happens already.
4.15 Ultimately, the aim must be for every journalist
to research and write every story with the Code in mind.
4.16 The text of a PCC adjudication should be
clearly and consistently set out to ensure its visibility and
easy identification as proposed by Sir Christopher Meyer, the
new Chairman of the Commission. However, we urge that the design
of this 'branding' must avoid duplicating the appearance of an
advertisement which may cause it to be skipped automatically by
some readers. (Paragraph 79)
4.17 The Government agrees that it would be a step
forward for PCC adjudication to be clearly identifiable; consistent
branding would be very helpful in achieving this.
4.18 We recommend that any publication required
to publish a formal PCC adjudication must include a prominent
reference to the adjudication on its front page - in effect a
'taster' for the judgement. (Paragraph 80)
4.19 We believe that it is important for the credibility
of the system for any adjudication to be given appropriate prominence.
4.20 In addition we recommend that the PCC's annual
report contains an additional feature-something familiar and popular
amongst newspapers-a league table showing how publications have
performed against the Code that year. (Paragraph 81)
4.21 We believe it is important to note that information
on adjudications and other complaints is already freely available
from the PCC; it is published on their website along with a helpful
facility that allows a search by newspaper, by Code clause, by
name, or any key word.
4.22 We believe that annotating press archives
as to their accuracy and sensitivity should be automatic in all
cases, and certainly all upheld adjudications, and furthermore
that the publication should be responsible for removing the relevant
article from publicly available databases. (Paragraph 82)
4.23 It is indisputable that newspapers should take
steps not to repeat inaccuracies and the annotation of databases
seems an important step in this process. While newspapers can
only annotate databases over which they have control, they should
also take appropriate steps to inform others of inaccuracies.
4.24 We believe that the PCC, Pressbof and the
industry would benefit, in terms of public confidence, if they
formed a consensus around two new elements of the system; one
gently punitive and one modestly compensatory:
i) Pressbof should introduce a gearing between
the calculation of the registration fee and the number of adverse
adjudications received by a publication in the previous year;
and
ii) the industry should consider agreeing a fixed
scale of compensatory awards to be made in serious cases (which
in any case according to the evidence from the industry and the
PCC are few and far between). If these were fixed in advance,
a matter of consensus and relatively modest, we can see no reason
for lawyers to be involved. Consideration could be given to the
making of an award to a charity of the complainant's choice rather
than directly. (Paragraph 83)
4.25 The Code covers an enormous range of publications
so what might be a modest compensatory payment by a national paper
would be punitive to very many smaller publications. Breaches
of the Code are very serious but it is not for the PCC to administer
a self-regulatory scheme which might result in the closure of
a newspaper. The PCC would also need to consider whether editors
would continue to participate in such a scheme, and there is a
distinct possibility that some - particularly some associated
with smaller local papers - would not. The introduction of financial
penalties could therefore be counter-productive.
4.26 The Committee believes that the involvement
of lawyers would be unnecessary, but it seems that editors do
not necessarily agree; for example, when Rebekah Wade gave evidence,
she indicated her belief that such a practice would inevitably
mean that lawyers would become involved and, in turn, that the
process would slow down.
4.27 That does not mean that financial penalties
are never appropriate, but if someone wants to pursue compensation,
there are legal options available to them and the Courts will
decide on the appropriate level of compensation.
4.28 We strongly urge the PCC and the industry
to consider the matter of complainants' costs and agree that,
where justified complaints have involved particular financial
burdens on the complainant such as the acquisition of a transcript
of a trial or inquest (but not legal fees), then those costs must
be met by the offending newspaper, which made the original claims,
to the complainant who has been found to have been traduced or
otherwise injured. In the light of the PCC's battle cry of "fast,
free and fair" we believe this to have nothing to do with
the debate over punitive or compensatory awards. (Paragraph 85)
4.29 We can see that this might be a particular issue
in complaints dealing with the accuracy of reporting, but it seems
less relevant to complaints about privacy, and it would of course
require a judgement about whether the expenditure was necessary
in the first place. This recommendation also raises the issue
of whether complainants should pay the costs where their complaints
are found not to be justified, yet have been pursued to adjudication
stage.
4.30 If the Board and the Code Committee are totally
unwilling to accept the introduction of lay members to the latter,
then we believe that the industry has a sufficient input into
agreeing the Code and that Pressbof should withdraw from the process.
(Paragraph 87)
4.31 The key point here is that this is a process
of self-regulation. In any case, there do not seem to be any criticisms
of the Code itself; criticisms have related to the way the Code
is interpreted.
4.32 We accept the offer to the Committee made
by Sir Christopher Meyer to return in a year's time to report
on progress. This offer will not, however, substitute for action
on our own initiative and we therefore recommend that the PCC
make itself available to give evidence to this Committee at regular
intervals for discussions on progress with its agenda for change.
(paragraph 88)
4.33 There is no reason to believe that the PCC would
show anything but co-operation.
4.34 We cannot see how the matter of illegal payments
to policemen can fail to fall within the criteria set out by the
PCC for taking the initiative, or how the issue is different to
the example of illegal telephone-tapping highlighted by the Commission
itself. We believe that the PCC must investigate. This may be
best accomplished in cooperation with the Information Commissioner
and the Police Complaints Authority and, if necessary, result
in an addition to the Code (such as occurred on intercepting telephone
calls). (Paragraph 96)
4.35 This again raises the question of whether the
Code should be duplicating the law. Setting that aside, and concentrating
solely on the question of newspapers making payments to policemen,
there are several laws that make it an offence for police officers
to receive payments for information: the Misconduct in a Public
Office Act, the Prevention of Corruption Act, the Data Protection
Act, and the Common Law. A police officer receiving payments would
also be subject to disciplinary procedures under the terms of
codes of conduct.
4.36 Of course, it would be for the courts to decide,
but in paying a police officer for information it is likely that
a journalist or editor would be guilty of bribery under the terms
of the Common Law and would contravene the Prevention of Corruption
Act. It may also be considered incitement to commit an illegal
act, and there is legislation which makes such incitement itself
illegal. Whether it is necessary for the Code to ban such activity
may depend on whether there is evidence that it is taking place.
In the evidence the Committee heard there were suggestions that
payments had been made in the past, but that the practice was
no longer current.
4.37 On the other side of the fence, we recommend
that the Home Office and police authorities also take note of
evidence from the editors of The Sun and the News of the World
to us regarding payments to police officers for information and
take steps to review and overhaul, if necessary, the guidance
measures aimed at preventing such behaviour by police and media.
(Paragraph 96)
4.38 The Government condemns corruption and the abuse
of power in all its forms, and believes that police officers who
abuse their position should be identified and dealt with. We believe
that Chief Officers of police are just as keen to root out instances
of corruption amongst their officers.
4.39 In February 2003 the Home Office published a
report called Police Corruption in England and Wales: An assessment
of current evidence (available on their website at http://www.homeoffice.gov.uk/rds/pdfs2/rdsolr1103.pdf
). The report establishes the nature of contemporary police corruption,
and "leaks to the media" were cited as examples of "information
compromise" which, it acknowledges, is a problem, particularly
in high profile cases. The report moves on to look at the causes
of this and other types of corruption, and examines the good practice
already available in investigating and preventing corruption.
4.40 The Police Reform Act 2002 includes provision
to afford police officers the protection of the Public Interest
Disclosure Act 1998. This allows an officer to report corruption
(or any other type of wrongdoing) with the assurance of protection
if he or she suffers for doing so. This is particularly important
if an officer sees corruption in a more senior officer. We hope
that this protection will lead to a more open police service.
Conclusion
5.1 The Government believes that people have a right
to a private life, but that right is not absolute. Equally, the
right to freedom of expression is not absolute. Where there is
conflict between the two, they must be weighed against each other.
The Government remains committed to supporting self-regulation
as the best possible form of regulation for the press, and as
the best possible way of balancing those sometimes conflicting
demands. There is, however, room for improvement in any regulatory
system, and the Committee's report has effectively opened up debate
on what the improvements in this system might be. We believe that
such debate is healthy and constructive, and that it should lead
to a positive outcome.
October 2003
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