Memorandum submitted by the The Editors'
Code Committee
THE EDITORS'
CODE COMMITTEE
The Editors' Code of Practice Committee, comprising
representative senior editors from Britain's national and regional
newspapers and magazines, writes, reviews and revises the Code
that sets the benchmark for the system of press self-regulation
administered by the Press Complaints Commission.
Its current membership is: Chairman: Leslie
Hinton, News International; Neil Benson, Trinity Mirror Regional
Newspapers; Adrian Faber, Express and Star, Wolverhampton; Mike
Gilson, The Scotsman; Jonathan Grun, Press Association; Douglas
Melloy, Rotherham and South Yorkshire Advertiser; Ian Murray,
Southern Evening Echo; Lindsay Nicholson, The National Magazine
Company; David Pollington, The Sunday Post; Alan Rusbridger, The
Guardian; Neil Wallis, News of the World; Harriet Wilson, Conde-Nast
Publications; John Witherow, Sunday Times; and Peter Wright, The
Mail On Sunday.
EXECUTIVE SUMMARY
— The Code can be seen to be comprehensive
and robust in all the areas raised by the Select Committee. The
protection of privacy is covered in 11 clauses of the Code, which
is constantly evolving and often innovative in scope and approach.
These strengths, inherent in a voluntary system, are not often
available in a statutory matrix. However, the self-regulatory
system is predicated on adherence to the law and expects that
those who cross the line will pay the appropriate price in the
courts.
— Just as the law cannot eradicate
crime, the Code cannot prevent all journalistic excess. But self-regulation
reduces lapses, improves standards and hastens remedies.
— Of the issues cited by the Select
Committee, the Goodman case was a clear breach of both the law
and Code and the law took the lead role. The journalist is in
jail. His editor has resigned. The strength and validity of the
Code in this area is not at issue.
— The Code already addresses the areas
raised by the Information Commissioner. While some of the assertions
of What Price Privacy? should be treated with caution,
and the case for custodial penalties has not been made, the Code
Committee will assist in providing better guidance and consider
the ICO's proposed amendment.
— The case of Ms Kate Middleton demonstrated
that where media interest becomes intrusive, there are well-tried
self-regulatory contingencies to cope with it within the Code.
They are effective and have been pioneered by the PCC.
— The self-regulatory system has led
on the issue of regulating online activity, an area that has proved
beyond normal statutory controls. It will bring an ethical dimension
lacking elsewhere on the Internet: another first for voluntary
self-regulation.
— The importance of the voluntary element
cannot be overstated. It allows constraints to be put in place
that would be inappropriate in law, and yet works alongside the
law. But the distinction between the two must be clear and maintained.
— While the Code supports the law,
it is not the law. The Code's role is as a powerful force in providing
an ethical framework for the British press. There are dangers
that, if it attempts to become a surrogate of the law, that will
threaten not only the basis of self-regulation but also be inimical
to the normal notion of a free press, both of which the Government
is pledged to protect.
1. Introduction
1.1 The committee welcomes the opportunity
to set out its views on the issues raised in the Select Committee's
current inquiry. The protection of the proper balance of respect
for privacy and of the maintenance of freedom of expression is
at the heart of the self-regulatory system. The Code is central
to that: a non-legalistic framework of commonsense rules by which
disputes may be resolved speedily, and effectively, without recourse
to slow, expensive and sometimes oppressive legal processes.
1.2 This does not put the press above the
law. The Code of Practice demands high journalistic standards,
and normal adherence to the penal code is implicit in that.
1.3 Current laws apply, to a greater or
lesser extent, in most of the areas identified by the Select Committee's
inquiry, including phone tapping, data protection and harassment.
Of course, the law in these areas is not 100% effective; it does
not totally eradicate crime. Similarly, the Code does not eradicate
all journalistic excess. But lapses are both reduced and remedied
more effectively by the existence of the Code and the self-regulatory
system, and legal incursions into this process could seriously
undermine that.
2. History and role of the Code
2.1 The self-regulation system is voluntary,
but relies on unchallenged compliance from within the industry.
So, while the Press Complaints Commission has a majority lay membership
to guarantee its independence, the Code is written and revised
by editors and then endorsed by the industry. The guiding principle,
since 1991, has been that only a Code drafted by editors would
command the necessary authority to deliver universal compliance.
2.2 The fact that editors also serve—albeit
as a minority—on the PCC increases respect for its judgments
across the industry. A complaint to the Commission is taken very
seriously and there is a genuine sense of failure and shame at
being found in breach of the Code. Steps are almost invariably
taken to minimise the risk of a recurrence. A measure of the industry's
commitment to the system is that no editor found to have breached
the Code has ever defaulted on the voluntary obligation to publish
a critical PCC adjudication. It is a record rarely, if ever, matched
internationally.
2.3 The Code cannot stand still and has
evolved over 16 years through constant revision, most notably
in 1997, following the death of Diana, Princess of Wales. In 2004,
the Code Committee introduced an annual review, inviting suggestions
for amendments to the Code from civil society.
2.4 As a result, the Code has been substantially
rewritten to improve clarity and to take account of changing circumstances
and public attitudes. For example, the zones of privacy have been
extended to embrace digital communications and the discrimination
rules expanded to cover individuals suffering prejudicial or pejorative
references about their gender.
2.5 The spirit of the Code: The existence
of a standing Editors' Committee within a voluntary system allows
the Code to require of editors obligations inappropriate in a
legal, or imposed, regime. Principal among them is that the Code
should be followed "not only to the letter but in the full
spirit." It also requires editors and publishers to implement
the Code and "to take care to ensure it is observed rigorously
by all editorial staff and external contributors, including non-journalists,
in printed and online versions of publications."[1]
2.6 These requirements give the PCC greater
latitude and extend the remit not only to freelancers and photographers,
but also to non-journalists, effectively embracing developments
in citizen journalism. Online versions of publications are included,
which—as will be seen—takes the process further than
have most other, parallel regulators.
2.7 Balancing rights: At the same time,
the Code protects publication that is genuinely in the public
interest, thus managing the balance between the rights of the
individual—such as to privacy—and the rights of the
public, including freedom of expression and the right to know.
2.8 While the Code, written by editors,
outlines the balance to be struck, interpretations are entirely
for the independent PCC to decide on a case-by-case basis, thus
determining much of the Code's effect by creating a body of case
law. The lay membership's influence in helping to shape journalism
is profound and ongoing, adding authority to the process.
2.9 The Editors' Codebook: In 2005, much
of this case law was gathered together in The Editors' Codebook,
an official handbook, which showed, through PCC adjudications,
how the Code worked in practice. It was sanctioned by the Code
Committee following the Select Committee inquiry into Privacy
and Media Intrusion, and published by the trade associations—The
Newspaper Publishers Association, the Newspaper Society, Periodical
Publishers Association, the Scottish Daily Newspaper Society and
Scottish Newspaper Publishers Association.
2.10 The book was a pioneering development
for self-regulation, both in Britain and abroad, and was praised
by the European Union Commissioner for Culture, Ms Vivien Reding.
Later this year, it is intended to put the Codebook online as
part of a new Editors' Code Committee website, where it will be
regularly updated with case law, Code changes and answers to frequently
asked questions. Both the book and the proposed website are a
testament to the British press industry's commitment to the process
of self-regulation, which in scale and scope is probably unparalleled
internationally.
2.11 Indeed, the UK Code of Practice is
widely used as a template by self-regulatory press regimes in
the Commonwealth and around the world. It is recognised as providing
breadth, depth and simplicity in a practical, achievable format,
rather than by setting Olympian standards unlikely to be observed,
and which are a familiar flaw in some overseas regimes.
Note: A hard copy of The Editors' Codebook
is supplied for each member of the Culture, Media and Sport Select
Committee as an appendix to this submission.[2]
3. The Code and the law
3.1 The Code of Practice does not set out
to replace or replicate criminal or civil law. That is not its
role, nor should it be. The Code will often ask more of journalists
than the law demands, but never less. However, their cultures
are distinct and their roles should not be blurred. The self-regulatory
system is a voluntary regime, which—while conducting itself
according to sound principles of natural justice—is by necessity,
as well as choice, essentially non-legalistic in approach. There
are sound reasons for this.
3.2 First, the Press Complaints Commission
has no vested legal standing or empowerment. It has no powers
of discovery, cannot summon witnesses, and relies on industry
adherence to voluntary obligations of co-operation rather than
on legal instruments of coercion. It also avoids the major disadvantages
of the legal system: legendary expense, complexity and slowness,
which often make it inaccessible to ordinary people.
3.3 Second, the non-legalistic and voluntary
approach permits greater latitude than is allowed in the penal
code. The spirit of the Code, for example, excludes wriggling
through loopholes as an option. The fact that the system is voluntary
means it is not subject to constant challenge, and an editor's
co-operation in trying to resolve the dispute is virtually guaranteed
(non-co-operation with the PCC is itself a breach of the Code).
These factors make the PCC an attractive route for dispute-resolution,
compared with recourse to civil law. However, the courts remain
an option, should complainants wish.
3.4 The criminal law is also available.
While neither the Code nor the PCC attempts to replicate the law,
adherence to the criminal code is both implicit and explicit within
the system. The preamble to the Code states at the outset: "All
members of the press have a duty to maintain the highest professional
standards." It is unthinkable that this should not include
normal adherence to the law, or that unlawful activity would be
condoned.
3.5 But if the case needed stating further,
it is made categorically in The Editors' Codebook three times.[3]
Most specifically, it sets out the position unequivocally on page
9: "Journalists must remember that they remain, as ever,
subject to the same legal constraints as every other citizen—such
as the laws of defamation, contempt, trespass, harassment and
a hundred others. The Code will often require more of journalists
than that demanded by law, but it will never require less."
This could hardly be clearer.
3.6 So the Code and the law are complementary.
The systems work while the two cultures remain distinct. Problems
arise if they become enmeshed. It is sometimes suggested that
the Code would be strengthened if it were amended to reflect the
law. That would be dangerous because the voluntary ethos would
be threatened and its benefits lost.
3.7 If the language of the law were incorporated
into it, a breach of the Code would automatically be a breach
of the law. Journalists committed to co-operating with the voluntary
system would be put at risk of subsequent prosecution in the criminal
court, a form of double jeopardy. The dangers of self-incrimination
would often be such that on strong legal advice they would not
be likely to co-operate. In the face of such advice, the PCC would
usually have to stand back. Its ability to act speedily, cheaply
and efficiently in an important area of its remit would be diminished.
3.8 The Code and self-regulatory system
are complementary to the law, creating an ethical penumbra around
it. But they are not agents of the law. They perform different
and separate roles. It is vital to a free press that the distinction
is maintained.
4. The Code and privacy
4.1 The protection of reasonable expectations
of privacy is central to the Code's purpose and to reflect that
privacy issues are covered to a greater or lesser extent in 11
of the 16 clauses. These are: Clauses 3, Privacy; 4, Harassment;
5, Intrusion into grief or shock; 6, Children; 7, Children in
sex cases; 8, Hospitals; 9, Reporting of crime; 10, Clandestine
devices and subterfuge; 11, Victims of sexual assault; 12, Discrimination;
and 14, Confidential sources.
4.2 The Select Committee has raised the
question of the efficacy of Code of Practice with particular reference
to the Clive Goodman case; the access to personal data highlighted
by the Information Commissioner; and the treatment of public figures
by photographers, clearly with Ms Kate Middleton in mind. These
issues are covered principally by Clauses 3, 4 and 10, and before
looking at their specific application to the cases mentioned,
we should examine the breadth and depth of protection those clauses
currently provide.
4.3 Clause 3, Privacy was last revised in
2004.[4]
The asterisk indicates that it is subject to a possible exception
if the action was in the public interest. The clause now states:
(i) Everyone is entitled to respect for his
or her private and family life, home, health and correspondence,
including digital communications. Editors will be expected to
justify intrusions into any individual's private life without
consent.
(ii) It is unacceptable to photograph individuals
in private places without their consent.
Note—Private places are public or private
property where there is a reasonable expectation of privacy.
4.4 The clause was substantially revised
in 1997, when zones of privacy were first included. The note defining
private places introduced the novel concept of a reasonable expectation
of privacy. It meant the PCC, with its lay majority, would decide
what was reasonable in the circumstances. In 2004, digital communications
were added to the zones of privacy and sub-clause ii was widened
to include all photographs of individuals taken in private places
without consent, unless there was a public interest.
4.5 The clause is comprehensive. It covers
newsgathering activity and breaches are not reliant on material
having been published. It embraces the spread of modern zones
of privacy, including digital information, which might also be
covered by data protection law. The issue of what is intrusive
is decided on the grounds of reasonable expectation, and the burden
is on the editor to justify intrusions. This gives the PCC wide
discretion to decide what constitutes an intrusion in any given
circumstances.
4.6 Clause 4, Harassment is equally unequivocal
and comprehensive,[5]
having been revised in 1997, following Princess Diana's death.
It states:
(i) Journalists must not engage in intimidation,
harassment or persistent pursuit.
(ii) They must not persist in questioning,
telephoning, pursuing or photographing individuals once asked
to desist; nor remain on their property when asked to leave and
must not follow them.
(iii) Editors must ensure these principles
are observed by those working for them and take care not to use
non-compliant material from other sources
4.7 Again, the Code targets newsgathering
practices, and specifies activities that might be unacceptable,
if persisted with. These include pursuing or photographing individuals
once asked to desist. Finally, editors are required not only to
control their own staff but also take care not to use material
from other sources that does not comply with the rules.
4.8 This is one of the tightest clauses
in the Code. It makes clear that otherwise legitimate journalistic
activity could become unacceptable if persisted with, once asked
to desist. This introduces an actual moment when the journalists
might be in breach, even without any publication. That element
allows the PCC to be pro-active in passing on "desist"
messages to editors from complainants. Once told that a complaint
has been received, or a "desist" message issued, editors
usually respond positively. The system has been very successful
in reducing complaints of harassment, by stopping the problem
at source.
4.9 Media scrums: Similarly, where large
numbers of journalists and broadcasters congregate—a media
scrum—otherwise valid media attention could become intrusive.
After the Select Committee raised this in 2003, the PCC and the
Code Committee led in setting up a cross-media system in which
the PCC acted as a clearing house for "desist" messages,
passing them on not only to press editors, but to broadcasters,
whose regulatory bodies were not pro-active pre-publication. It
has been successful in dissipating the media pack and the problem.
4.10 Clause 10, Clandestine devices and
subterfuge[6]
Britain has an honourable tradition of investigative journalism
which, by its nature, often necessitates resort to practices that
would normally be off-limits. The two clauses covering activities
such as the use of listening devices and subterfuge were combined
in 2004, to delineate the ethical boundaries and embrace a spectrum
of surveillance methods. Clause 10 states:
10 *Clandestine devices and subterfuge
(i) The press must not seek to obtain or
publish material acquired by using hidden cameras or clandestine
listening devices; or by intercepting private or mobile telephone
calls, messages or emails; or by the unauthorised removal of documents
or photographs.
(ii) Engaging in misrepresentation or subterfuge,
can generally be justified only in the public interest and then
only when the material cannot be obtained by other means.
4.11 The Clause now covers explicitly or
implicitly the range of clandestine techniques, from hidden cameras
to bugging devices and telephone taps, or text or email intercepts,
thus reinforcing Clause 3's protection of digital communications.
Even to seek to obtain such information by such means would breach
the Code unless there was a public interest to justify it. That
is a major barrier to their use, or abuse.
4.12 The public interest in publishing or
obtaining information is a key factor in many areas of the Code,
and never more than when the right to privacy has to be judged
against the right of freedom of expression or the right to know.
The public interest exception is available in nine of the Code's
16 clauses, signified by an asterisk in the title.
4.13 The Code includes a non-exhaustive
list of areas that might justify the public interest exception.[7]
It states: "1. These include, but are not confined to: (i)
Detecting or exposing crime or serious impropriety. (ii) Protecting
public health and safety. (iii) Preventing the public from being
misled by an action or statement of an individual or organization.
2. There is a public interest in freedom of expression itself.
3. Whenever the public interest is invoked, the PCC will require
editors to demonstrate fully how the public interest was served.
4. The PCC will consider the extent to which material is already
in the public domain, or will become so. 5. In cases involving
children under 16, editors must demonstrate an exceptional public
interest to over-ride the normally paramount interest of the child."
4.14 The list demonstrates that the balance
will be struck in solid areas of the public's right to know, rather
than in the margins of public prurience. The burden of proof rests
on the editor. In cases involving children, it invokes a higher
threshold—requiring editors to demonstrate an exceptional
public interest to over-ride the paramount interest of the child.
These are substantial hurdles, reflecting the high thresholds
throughout the Code, especially those concerning privacy. The
Code is no pushover for errant journalists to exploit. It is comprehensive,
tough—and it works.
5. The Code and the Goodman case
5.1 As with the other privacy issues raised
by the Select Committee, the Clive Goodman prosecution was for
a practice proscribed by both the law and the Code. Although the
seriousness of the offence made it appropriate to be dealt with
by the courts, under the terms of the Code it would have been
just as much an open and shut case had it come before the PCC.
5.2 So in deciding whether the Code of Practice
in some way failed, it is necessary first to define success. If
the test is the deterrent value in preventing breaches, then arguably
there has been a failure of the Code. But equally there has been
a similar failure of the law, with its much greater range of vested
powers.
5.3 However, the law is not judged solely
by its deterrent effect. If it were, prisons would not be overflowing.
And if deterrent value is not a suitable test for the law, should
it be so for the Code? Goodman broke the law, pleaded guilty and
he is serving a four-month sentence. His action was indefensible
and no one has attempted to defend it. He paid a very high price,
as did his editor, who resigned as a result of the case. The clearest
message has gone out that such action will not be tolerated.
5.4 It would be for the independent PCC
alone to decide on any wider action to ensure compliance with
the Code in this or future cases. The Commission has initiated
its own inquiry and has sought assurances from editors that their
working practices conform with the Code in this area.
5.5 Could the Code have done more? The Code's
privacy clause refers specifically to respect for digital communications".[8]
There is a further provision in Clause Ten, covering clandestine
devices and subterfuge, which includes: "The press must not
seek to obtain or publish material acquired by using hidden cameras
or clandestine listening devices; or by intercepting private or
mobile telephone calls, messages or emails [...]"[9]
5.6 Undeniably, the Goodman breach was doubly
damned by the Code, which could not have been clearer. No Code
change appears necessary. Therefore, most debate on providing
greater deterrence might normally centre on whether the Code's
range of sanctions would have been sufficient. However, that is
academic, given the existence of the law with a maximum two-year
jail sentence. That was the ultimate deterrent. It did not work.
5.7 The Goodman case was shocking. But it
demonstrates that however clear the language of the law, and however
strong the sanction, a determined individual will always be tempted
to ignore them. The low number of prosecutions of journalists,
and close experience of the way in which they generally operate
according to the Code, suggests at the very least that members
of the press are no more likely than others to cross the line.
They will not be totally immune. That is not a failure of the
Code, any more than it is of the law.
5.8 The Editors' Committee is always open
to constructive suggestions on how it might improve the Code and
will consider any current options in its annual review in March.
6. The Code and the Information Commissioner
6.1 The Code Committee has engaged directly
with the Information Commissioner since the publication of What
Price Privacy? During the discussions, the Commissioner accepted
that the evidence collected by police in Operation Motorman in
2002 did not necessarily establish any breach of either the law
or the Code.
6.2 It established only that newspapers
had paid for information that was covered by the Data Protection
Act. Such activity would be permissible—under the law, as
well as the Code—if the information obtained was in the
public interest. No attempt has been made to establish whether
such a defence existed in any of the cases cited. The working
assumption was that the scale of press payment and the nature
of the information sought suggested a large illegal trade. That
may or may not be the case. We do not know.
6.3 However, a working assumption based
on circumstantial evidence would be insufficient to secure a conviction
and should be treated with due caution. This is particularly the
case where the legality of the activity hinges on the presence
or absence of a public interest defence.
6.4 Experience in investigative journalism
has shown that, while there may be reasonable grounds to believe
there is a public interest in an inquiry, by its nature it is
often not possible to prove that interest at the outset; if it
were, there would often not be any need for the investigation.
The case for introducing jail sentences for journalists in this
area has not been made. The current law allows for unlimited fines,
but has been rarely used. Custodial sentences would have a chilling
effect on investigative journalism and would be likely to seriously
limit the PCC's scope in this area.
6.5 What is beyond doubt is that if such
an illegal trade in personal information existed, it would clearly
breach the Code, and the Editors' Committee would condemn it.
The committee has therefore indicated to the Commissioner its
willingness to assist in industry-wide initiatives to raise awareness
of the issues raised in his report, notably the drafting—in
close consultation with the ICO if he wishes it—of simple
guidance for journalists. We intend to include such guidance in
an online version of The Editors' Codebook to be launched
this year.
6.6 However, the Commissioner seemingly
wishes the committee to amend the Code to bring it more in line
with the Data Protection Act. As shown, (paras 3.7-3.8) there
are problems with the Code appearing to echo the law and these
would need to be resolved.
6.7 The Commissioner suggests there should
be a third sub-clause to Clause 3, Privacy, which would state,
subject to a public interest exception:
(iii) It is unacceptable, without their consent,
to obtain information about any individual's private life by payment
to a third party or by impersonation or subterfuge. It is unacceptable
to pay any intermediary for such information which was, or must
have been, obtained by such means.
6.8 Although the Code Committee has yet
to formally consider the suggestion—and will do so in March—a
possible issue is that the Information Commissioner's wording
appears to go beyond the remit of either the current Code or the
law. First, it makes the obtaining of any private information—not
just protected data—an automatic breach, thus widening the
remit. Second, it makes the act of payment to a third party a
critical test. This would bring a new dimension to the Code, where
the current test is whether a failure to respect digital communications
constitutes an intrusion into privacy. If it does, it is unacceptable,
whether or not payment is involved.
6.9 It seems curious that an activity that
is acceptable without payment becomes unacceptable if money is
involved. Is information automatically tainted by payment? Would
a genuine intrusion of privacy be any less so, if payment had
not been made?
6.10 However, the Code Committee will consider
the proposal as part of the annual Code Review and decide on any
amendment. Any alternative wording would normally be discussed
with the Commissioner before a final decision was taken.
7. The Code and the treatment of public figures
by photographers
7.1 The media attention surrounding Ms Kate
Middleton might appear to raise similar issues of privacy as in
the Goodman case, because of the royal connection. But, Prince
William apart, the issues were very different. Goodman's activity
was calculated and illegal. In Ms Middleton's case there was,
for valid reasons, a spontaneous explosion of international media
interest whose effects needed to be dissipated.
7.2 An outburst of media interest is not
against the law or the Code, and could be legitimate in many circumstances.
Those would include responding to intense speculation that the
subject of the attention might soon be named as a future Queen,
a matter greatly in the public interest.
7.3 But the presence of large numbers of
press and broadcasting personnel could itself be intrusive, and
so while the media interest might not itself breach the Code,
a failure to manage it could do so. As previously mentioned (paras
4.8-4.9), the self-regulation system has pioneered arrangements
to cover this after a "desist' message has been issued. In
Ms Middleton's case—as with many others—a "desist"
request was made and acted upon, via the PCC. The media scrum
quickly dispersed.
7.4 Whether this was sufficient remedy in
all the circumstances, might yet have to be decided by the PCC,
and it would be improper to anticipate that. But what is clear
is that a voluntary, workable mechanism exists to manage the problem;
it is used regularly with success; and it is effective in a way
legal constraints could rarely be.
7.5 Properly used, and recognising the balance
of legitimate media interest and the right of privacy, this system
is not a flaw of self-regulation, but one of its many quiet triumphs.
8. The Code and the regulation of online news
8.1 Regulation of the online press is another
innovative area. Although control of the Internet has long been
seen as unsuited to statutory regulatory processes, online versions
of newspapers and magazines have been within the voluntary Code's
remit since 1997. To keep pace with developments of digital publishing,
such as the increasing use of audio-visual material, PressBof
and the industry have co-operated to produce clear, simple guidance
on which areas of online publishing should fall under the Code.
8.2 The guiding principle has been the extent
to which the material appearing on the newspaper and magazine
websites can be judged to have been properly the responsibility
of the editor. This would rule out, for example, user-generated
material, such as chat rooms and blogs, and streamed or syndicated
material that was live—and therefore not subject to editing—or
pre-edited to confirm to the standards of another media regulator.
8.3 These guidelines fit with the Code's
general approach, which is to have rules that are pragmatic, flexible
and achievable. The test of editors' responsibility meets with
users' expectations and it means the relevant online material
will match the ethical standards of the press generally. Thus,
issues of taste and decency, and the right to editorialise for
example, will be matters for the editors' discretion, but obligations
of accuracy, privacy, and so on will be covered by the Code.
8.4 The strength of this is that it will
provide users of newspaper and magazine websites with a clearly
stated ethical benchmark, backed up by a system of remedying breaches,
neither of which will be matched in most other areas of cyberspace.
February 2007
1 Preamble to the Code, The Editors' Codebook
p 93. Back
2
Not printed. Back
3
Codebook, p 7; p 9; pp 14-15. Back
4
Codebook, p 33. Back
5
Codebook, p 41. Back
6
Codebook, p 65. Back
7
Codebook, p 88. Back
8
Codebook, p 33. Back
9
Codebook, p 65. Back
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