Memorandum submitted by the Consumers'
This evidence by Consumers' Association (CA)
focuses on a number of key issues for consumers, rather than attempting
to deal with the entire scope of the Bill. We will respond to
the draft Bill in full at a later date.
Deregulation should not be an OFCOM policy objective
in itself, rather the aim should be to achieve appropriate levels
and forms of regulation. The pace of change must follow actual
consumer needs and expectations, rather than technological progress.
Improved consumer representation is central
to effective and appropriate regulation, including co-regulation.
The proposed Consumer Panel and Content Board should be more fully
integrated into the regulatory processes outlined in the draft
The nature of the Consumer Panel's relationship
with OFCOM is central to its effectiveness. It must have genuine
independence of remit and resources, but also direct access to
regulatory information and decision-makers.
There is the potential for conflict between
effective economic regulation and OFCOM's other policy objectives.
OFCOM's key objective, and measure of success, should be ensuring
an effective market, which serves consumers well.
The Telecoms Ombudsman scheme is a key test
of whether industry is willing to take responsibility for further
self-regulation. OFCOM must be actively involved in proposing,
trialling, and monitoring any further such initiatives to ensure
that they are fit-for-purpose.
The draft Bill proposes greater reliance on
competition law rather than sector specific regulation in communications.
This will require a clear division of responsibility between OFCOM
and the OFT, and consistency with the Enterprise Bill.
It is important for OFCOM to ensure coherence
by regulating all 3 tiers of broadcasting. The regulator cannot
deliver on its duties relating to an overall public service broadcasting
remit without greater oversight of the BBC.
CA urges the Joint Committee to ensure that
the consumer voice is adequately represented in the debate over
the draft Communications Bill by taking oral evidence from CA
and other consumer representatives.
For further information, please contact:
Peter Jenkins (Senior Public Affairs Officer)
020 7770 7612 email@example.com or
Allan Williams (Senior Policy Officer) 020 7770
Consumers' Association (CA) is an independent
UK consumer organisation with over 700,000 members. Entirely independent
of Government and industry, we are funded from subscriptions to
our consumer magazines and books, including Which?. We
are also a member of BEUC, the umbrella organisation of European
consumer bodies. Our Director is Dame Sheila McKechnie.
The history of CA involvement in communications
policy issues can be traced back a quarter of a century to the
deliberations of the Annan committee on the future of broadcasting.
More recently we have produced policy reports on issues of consumer
representation, communications regulation and ombudsman schemes.
CA is involved more directly with alternative forms of regulation
through establishing Which? Webtrader, a self-regulatory
scheme for e-commerce. In addition we have participated in the
DCMS Viewers' Panel, the Telecoms Ombudsman working group, and
continue to be involved in the government's Digital Action Plan.
CA is concerned by the assertion at the beginning
of the draft Bill that deregulation will necessarily bring benefits
for consumers as well as businesses. Deregulation should be contingent
on whether competition and industry co-operation can deliver the
same benefits as formal regulation. CA has welcomed the more realistic
"carrot and stick" approach to co- and self-regulation,
which has recently been adopted by Oftel, and we urge the committee
to consider whether deregulation should be a policy objective
The policy document (3.1.2) masterfully understates
the way that OFCOM's raison d'etreconvergencehas
been undermined by rapid changes in the fortunes of the industry
and much slower changes in consumer demand. While convergence
in networks and services has been extensive, CA reports on digital
television and Internet usage have demonstrated that few consumers
change as seamlessly between various means of reception and communication.
Consequently, there is a need to ensure that reform does not run
ahead of consumers, ensuring that existing forms of regulation
are maintained where necessary.
Despite this, there remain good reasons for
regulatory reform. CA has argued in favour of a converged regulator
for the communications industries since 1997,
but it is clear that OFCOM cannot deliver benefits without attention
to the purpose of these reforms and the challenges that OFCOM
will face to deliver on them. CA believes that the key purpose
of regulatory reform should be to advance the consumer interest,
through promoting effective markets where possible, and through
providing more formal protection where necessary.
CA urges the Joint Committee to consider whether
the consultation process has allowed effective input and scrutiny
process of the draft Bill, in particular the release of additional
media ownership clauses and changed to the BBC agreement after
its publication. We also note that much of the detail of the proposed
regulatory regime will be set out in statutory instruments and
other secondary mechanisms. It is important to ensure proper Parliamentary
scrutiny of all the proposed reforms, and adequate consumer input
into this process.
The need for improved consumer representation
is aptly illustrated by the difficulties encountered by consumer
representatives in responding to the Joint Committee within the
short timescales allowed. One of the Bill's key provisions recognises
the need for consumer representation to be properly resourced
within the regulatory structure, in order to ensure effective
input into policymaking and to redress the balance of lobbying
power with industry. We trust that the Joint Committee will also
ensure that this balance is maintained by taking evidence from
consumer representatives as well as industry and the existing
CA believes that there are clear benefits to
be derived from the creation of OFCOM, but that these will not
be delivered simply by creating a single, more coherent structure
(3.1.5). We would urge the Joint Committee to consider how OFCOM
will operate and set priorities where there is currently overlap
(eg on EPGs, which raise both content and economic issues) or
gaps (eg digital switchover) between the existing regulators.
It is vital that legislation adequately defines how the existing
regulators' priorities and approaches are to be taken forward
within OFCOM. It may also be that, in some cases, integration
and the ability to respond to technological change may lead to
OFCOM identifying a need for new forms of regulation, rather than
CA also urges the Joint Committee to consider
how OFCOM will discharge the range of wider public policy priorities
set out in the draft Bill (3.1.6). While objectives such as the
promotion of media literacy are welcome, they raise some concerns.
Firstly, they are not part of the existing regulators' remits,
and will requite additional skills, staff and resources if OFCOM
is to carry them out effectively. Secondly, there is the potential
for conflict between efficient regulation and other public policy
priorities, as recent criticism of Oftel's approach to broadband
roll-out has demonstrated. It is possible to foresee tensions,
for instance, between priorities relating to deregulation and
consumer protection. It is therefore essential to ensure that
OFCOM's core objective is effective economic regulation in the
consumer interest, rather than other public policy priorities.
Although we agree that OFCOM should not regulate
the Internet in any formal sense (3.2.2), the benefits of the
network economy which the draft Bill anticipates are largely dependent
on consumer confidence. Consumers do not necessarily need to know
how or by whom they are protected, only that an appropriate level
of protection is in place. This does not necessarily mean that
they expect the same levels of protection online as elsewhere:
sometimes less eg over content; sometimes the same eg advertising
standards; sometimes more eg data protection.
CA itself has developed a self-regulatory scheme for e-commerce,
Which? Webtrader, but we do not share the government's
optimism that all issues can be left to self-regulation. As convergence
progresses, it is vital that OFCOM should have backstop powers
and be able to step in where industry cannot or will not take
a responsible attitude to consumer protection.
Consumer advocacy fulfils a complimentary but
quite different role to regulation. Effective consumer representation
in communications is needed both to redress the existing lack
of attention to consumers, and to reflect the potential for consumers
to both shape and be profoundly affected by technological change.
It is central to preventing market and regulatory failure, ensuring
both access and efficient regulation. CA has argued that representation
should distinguish issues of economic regulation (choice, value,
redress, disadvantaged consumers etc.) from those relating to
We therefore welcome the twin approach outlined in the draft Bill.
CA welcomes the governments intention to ensure
that OFCOM is accountable to its stakeholders, but the language
of the draft Bill is at best unclear in identifying who they are.
Various terms are used to describe the consumer in the draft Bill
and supporting documents: customers; persons; citizens; the public;
end-users; and domestic and small business customers used jointly.
CA is particularly concerned that the definition of customers
may be limited to those who are in a contractual relationship
with a provider, excluding many (eg those who are unable to access
a service or who are indirectly affected by it) from OFCOM's protection.
It is essential that OFCOM should have a duty to protect all consumers
and citizens, not just those who are purchasers of particular
goods and services.
The draft Bill proposes to create a Content
Board and a Consumer Panel, which CA warmly welcomes, but we urge
the Joint Committee to seek greater clarity on a number of issues.
Firstly, it is essential to ensure that the roles of the two bodies
are distinct, and that the relationship between them is adequately
defined. Secondly, the nature of their input into OFCOM decision-making
should be clarified and highlighted throughout the legislation,
particularly in relation to the withdrawal of formal regulation.
Thirdly, there are a range of practical issues concerning appointments,
budgets, access to information, remit-setting and the need for
representation of all consumers. These issues are addressed below.
The Content Board
Although CA itself does not have a remit for
content issues, we support the proposed creation of a Content
Board (4.1). It is important to maintain the current level of
lay input and representation of particular groups within the structure
of content regulation, particularly on issues of standards. OFCOM
should ensure that this body is more diverse and representative
of all consumers than the existing bodies, including disadvantaged
groups, elderly and disabled consumers, and members from all regions
and nations of the UK. Experience suggests that this can be more
easily achieved through ensuring time-limited appointments, adequate
resources, training, access to expertise and a clear remit.
Although the work of the Board will largely
be defined by OFCOM itself (4.1.3), it may be useful to define
some of its responsibilities and powers in legislation. Given
the expectation that minimum content standards will be flexible
in relation to changes in audience expectations, OFCOM should
be obliged to consult the Board when considering changes. As with
the Consumer Panel, the board should also have a right of access
to OFCOM information and complaints data, and to research commissioned
by OFCOM and the Consumer Panel (4.1.6).
The Consumer Panel
At a practical level, it is essential that the
consumer interest should provide a counterbalance to the industry
and other interests seeking to shape regulatory decision making.
CA therefore welcomes the proposals in the draft Bill for a Consumer
Panel to advise OFCOM. However, we are concerned by the suggestion
in the draft Bill that the Panel's role should be restricted to
issues of access, service delivery and consumer protection (4.2.3),
and by unnecessary restrictions on its access to information.
We agree that the Panel should only have limited responsibilities
to address content issues.
At a strategic level, in the context of a regulatory
regime focusing so heavily on the promotion of competition, it
is vital that the consumer voice is heard on all the key issues
of economic regulation. The Panel's ability to publish opinions
and the duty placed on OFCOM to give public reasons when it disagrees
(4.2) is consistent with the "supercomplaint" regime
proposed in the Enterprise Bill, under which bodies including
CA can ask the OFT to investigate competition concerns in "problem"
sectors. CA urges the Joint Committee to explore the extent to
which the Consumer Panel can adopt a parallel role within OFCOM.
CA is extremely concerned that the draft Bill
fails to deliver on one of the key advantages of the Panel's semi-detached
relationship with the regulatorthat of access to informationby
maintaining the regulator's discretion to withhold information
which is commercially confidential or provided in confidence (Clause
96.6). Such discretion has historically prevented adequate scrutiny
of regulatory decisions, such as Oftel price controls, based on
confidential data. Such clauses not only exclude OFCOM from the
provisions of the Freedom of Information Act which are intended
to promote corporate and regulatory accountability, but are entirely
unnecessary, since companies are already protected from harmful
disclosure by the public interest tests contained in that Act.
CA urges the Joint Committee to recommend the removal of this
provision, in the interests of ensuring the effectiveness of the
Consumer Panel in advising OFCOM.
It is regrettable that the Panel's remit is
barely mentioned elsewhere in the draft Bill, given its importance
to effective and accountable regulation. The Panel will also need
to provide effective input to OFCOM on competition issues, ensuring
that analyses of effective competition consider whether markets
are effective for consumers, paying particular attention to disadvantaged
consumers. The Panel should also be closely involved when considering
rolling-back formal regulation. CA has worked closely with Oftel
and industry on the telecoms Ombudsman scheme and a code of practice
on disconnections, and further moves towards greater co- and self-regulation
will require the involvement of consumer representatives, which
the Consumer Panel should provide.
For these reasons, the Consumer Panel's independence
must extend to the ability to define its own remit, which may
extend beyond that of OFCOM. This is essential if the Panel is
to advise other bodies (4.4.3), avoiding the danger of regulatory
capture or being seen as OFCOM's Panel. While we agree that the
Consumer Panel is not best placed to handle content issues, it
should be able to consider them at the request of the Content
Board or where they raise competition concerns (eg relating to
programme supply and rights) without an invitation from OFCOM
(4.2.3). This independence of remit also requires adequate resources
to ensure that the Panel is able to undertake proactive work in
addition to the legitimate demands of advising OFCOM.
Regarding the composition of the panel, it is
essential not to confuse and conflate the many different elements
of effective consumer representation. Representation, consultation,
research, lay input and expert advocacy are all necessary but
distinct roles, which may be performed by OFCOM, the Consumer
Panel or the Content Board. However, CA believes that the role
of the Consumer Panel should be primarily one of expert consumer
advocate, along the lines of the Financial Services Authority
(FSA) Consumer Panel. Although the Panel should have a dutyand
access to adequate resources and adviceto represent the
interests of all groups of consumers, it may not be possible for
it to be representative in a strict sense. On issues relating
to appointments, we are content that the draft Bill follows the
Complaints and disputes
It is essential for consumers to have access
to rapid and accessible alternatives to the courts in order to
obtain redress. CA has worked closely with Oftel and industry
to propose and develop a telecoms Ombudsman scheme, and we welcome
the approach set out in the draft Bill. We regard the scheme as
a test for whether self-regulation can deliver the same standards
of consumer protection as formal regulatory mechanisms. The scheme
also presents a challenge to operators to deliver on the oft-stated
desire to achieve appropriate levels of consumer protection through
greater self-regulation. CA would urge to Joint Committee to seek
greater clarity in legislation over the timescales for, and levels
of, industry participation required for schemes to be judged adequate
by OFCOM (Clause 41.2).
Light touch regulation
CA is against the presumption that the majority
of regulatory objectives can be reduced to or achieved through
the promotion of competition and the roll-back of formal regulation.
The White Paper suggested that OFCOM would be over-reliant on
industry to deliver its primary duty of protecting the consumer
interest, and would only take action if industry failed to develop
codes and mechanisms to provide adequate consumer information,
protection and redress. We are pleased that the draft Bill takes
a more realistic approach to co- and self-regulation, recognising
that relying primarily on industry to protect consumers could
fatally undermine OFCOM's own primary duty to protect consumers.
As already indicated, CA is concerned that deregulation
should not be a policy objective in itself. We welcome the suggestion
that regulation should be rolled back "where no longer needed"
(3.1.1), but this requires extreme clarity on how regulation is
deemed to be unnecessary, and the extent to which it can be rolled
back. In many key areas such as universal service, regulation
is designed to protect disadvantaged consumers whom the market
does not protect or serve adequately, and to deliver wider public
policy goals relating to social inclusion. Consequently, the ultimate
test of efficient and appropriate regulation is its effectiveness
in protecting and delivering benefits to consumers.
It is crucial that OFCOM takes a lead in proposing,
brokering, trialling and reviewing areas where regulation might
be rolled-back. Legislation must require OFCOM to take full account
of actual consumer behaviour and needs and not technological potential,
industry promises or simple trend analysis when considering the
withdrawal of regulation. The regulator should also retain strong
backstop powers to limit and sanction co-regulatory failure in
the short term, and to maintain its efficient operation in the
future. CA believes that criteria and mechanisms for evaluating
the success of alternative forms of regulation should be established
as a matter of urgency.
We would also welcome greater clarity regarding
the grounds on which industry codes will be judged to have failed
and OFCOM will take action. Any withdrawal of formal regulation
should be conditional on ensuring that consumers remain protected
by and represented within alternative regulatory structures. Co-regulatory
schemes with adequate consumer involvement and regulatory backstop
powers would deliver equally flexible light touch regulation without
the disadvantages associated with self-regulation, but there are
important resource implications. The Consumer Panel will have
a key role to play by representing consumers in these processes.
CA welcomes the recognition that competition
provisions need to remain both flexible and contextual. However,
while supporting the general position, we are concerned about
the potential for confusion of responsibility between OFCOM and
the OFT which concurrency provides. We are also concerned about
the reliance on the discretion of the regulator to apply either
general or sector-specific competition rules. We would urge the
Joint Committee to consider two issues: the need for a clear division
of responsibility between OFCOM and the OFT; and the need to ensure
consistency between the Enterprise and the Communications Bills.
At the moment, it is unclear how OFCOM will
exercise its competition powers, given the ongoing reform of both
communications and competition regulation. The "competition
agency as watchdog" role is centrally important to advancing
consumer welfare. The prevention of competition abuse is hindered
by the complex web of firms, regulations, market structure and
established patterns of market behaviour by firms and consumers,
so it will be essential for OFCOM to use its knowledge of the
sector to ensure that the competition regime in communications
is consistent with that applied by the OFT.
The Enterprise Bill contains a number of key
provisions which CA would like to see mirrored in the final Communications
Bill. CA has particularly welcomed the powers given to the OFT
in respect of industry codes of practice. In a lighter-touch regulatory
system, consumers may increasingly rely on codes as a reassurance
that they are selecting a reputable firm. Unfortunately some codes
of practice are largely cosmetic and offer little consumer protection.
Although we welcome the procedures for the approval of codes in
the draft Bill (Clause 40), CA would like greater detail on the
grounds for approval. We look forward to OFCOM ensuring that codes
are both effective and meaningful to consumers.
CA is keen for consumer organisations to assist
with ensuring markets work effectively, so we are pleased to see
that super-complaints will be given a statutory basis in the Enterprise
Bill. It is envisaged that super-complaints will concern situations
where markets rather than the activities of particular companies
fail to work for consumers. CA also supports the new approach
to market investigation, combining of the complex monopoly provisions
with the ability to seek out problem sectors. However, as with
all such reforms their success will depend on the willingness
of the agencies to use their powers fully. We would expect OFCOM
to work closely with the Consumer Panel to identify and address
such problem sectors.
We would urge the Joint Committee to consider
whether the operation of an effective competition regime in communications
may be compromised by other public policy objectives, particularly
if OFCOM is responsible for their delivery. CA is particularly
concerned that, as in the case of broadband roll-out and analogue
switch-over, dominant players may be allowed to reinforce and
perpetuate their dominance in the interests of achieving particular
policy goals. This creates a clear conflict of interest if the
regulator is responsible for both effective competition in the
consumer interest, and the delivery of other public interest objectives.
Networks and services
CA urges the Joint Committee to consider the
EC directives on electronic communications as part of its deliberations.
We are concerned that their implementation through Statutory Instruments,
rather than alongside the draft Bill, may mean that they are not
given adequate Parliamentary scrutiny. Related to this, there
is a danger that the obligation on OFCOM to contribute to the
development of the internal market may lead to "levelling-down",
in the interests of harmonisation. It is essential to ensure that
existing forms of UK consumer protection are maintained in the
implementation of the EC directives.
CA welcomes the powers of direction on issues
of spectrum management which the draft Bill maintains. Although
we recognise the merits of relaxing the rules restricting spectrum
to particular uses, there are a number of concerns about the initial
auction and subsequent trading of spectrum.
Consumers participate in these markets indirectly through the
purchase of equipment and services, and are therefore vulnerable
to the impacts of spectrum trading on costs, longevity, quality
and access to these products. CA is concerned that the introduction
of spectrum trading should not be considered an end in itself,
but should only be introduced with adequate safeguards and where
it is likely to deliver measurable benefits for consumers.
These powers of direction are particularly important
or the management of the proposed switchover from analogue to
digital television. CA remains adamant that no reallocation of
broadcast spectrum can be considered until the switch-off of the
analogue television signal has been successfully completed, ensuring
universal access to free-to-air digital services. Spectrum reserved
for public service broadcasting should include sufficient capacity
for future enhancements to terrestrial broadcasting, such as local
public service broadcasting and interactivity. CA does not support
the proposed application of spectrum pricing to public service
broadcasters, nor the sharing of their spectrum allocations with
commercial users without further analysis of the effect on service.
OFCOM and the BBC
CA has long argued that OFCOM should have a
greater role in regulating the BBC, for two reasons: to ensure
effective and accountable regulation of the BBC against its public
service remit; and to ensure that OFCOM can effectively oversee
the whole broadcasting ecology. This is not some spurious argument
about "levelling the playing field", rather such reform
is vital to the legitimacy of both the BBC and OFCOM. CA is disappointed
that the draft Bill tends to support the BBC's own position, which
argues that it is enough to bring regulation of the BBC closer
to that of other broadcasters.
While we support the application of the programme policy statement
process to the BBC, this alone does not address our concerns.
To deal first with the BBC's own accountability,
we are not convinced that the BBC's editorial independence depends
upon, or is even a function of, the opaque and unaccountable way
in which it is governed. The recent reforms of the Governors appear
to be merely a response to the perceived threat of OFCOM oversight,
consisting of little more than a reorganisation of the executive
secretariat. Ironically, the best guarantee of the BBC's future
independence, distinctiveness and the legitimacy of its funding
is to ensure adequate oversight within OFCOM.
As a shadow for OFCOM and a consumer representative
on issues of economic regulation, the Consumer Panel needs to
scrutinise the competition implications of content issues, including
choice, access and pluralism. The BBC current arrangements substitute
lay advice (from bodies which are not adequately representative)
and general research (which is designed mainly to give legitimacy
to the BBC's own proposals) for genuine consumer consultation
and representation of the sort which will be provided to OFCOM
through the Consumer Panel (properly resourced, expert, with access
to research and the ability to get its opinions published and
considered. The Panel's remit therefore has to include the BBC
Moreover, it makes no sense for OFCOM to be
responsible for the delivery of a general public service remit
if it neither agrees nor monitors the remit of the BBC. The increasing
complexity of the broadcast market means that broadcasting regulation
needs to be viewed holistically, to ensure that the BBC's complex
relationship with the market is not reduced to merely addressing
market failure or duplicating existing offerings.
The fact that the BBC's performance, measured against its own
aims and promises, will be measured and reported on by the BBC
clearly undermines that role. Bringing enforcement of the BBC's
remit under OFCOM would deliver on the draft Bill's intention
to ensure coherent regulation across all broadcasters (220.127.116.11).
CA welcomes the proposed 3 tier system of content
regulation, and the proposed approach to setting basic standards.
As already suggested, it is vital that there should be adequate
consumer input into setting these standards, particularly if it
is anticipated that these will change to reflect changes in social
attitudes and audience expectations (8.5.1). This will be a key
role for the Content Board, through advice and research provided
by the Consumer Panel. CA supports the proposal that OFCOM should
consider content complaints from viewers, and we suggest that
the regulator also should take the nature and volume of these
into account in setting basic standards.
Improved media literacy will also be necessary
in a lighter-touch regulatory environment, and we welcome OFCOM's
responsibilities in this area (8.6.5). However, we are concerned
that OFCOM should not allow technologies such as filters or "net
nannies" to substitute for genuine media literacy which allows
consumers to protect themselves. As suggested above, it is also
important that this policy objective is supported by adequate
staff and resources, as it is not part of the existing regulators'
CA has been extremely critical of self-regulation
of advertising and the Advertising Standards Agency (ASA) in particular,
and we believe that technological change is likely to exacerbate
rather than improve the situation. This is an area in which convergence
is increasingly evident, with advertising campaigns commonly co-ordinated
between broadcast and print media, direct marketing, company websites
and other channels. The Internet has eroded the distinction between
advertising and editorial content, while allowing advertisers
to provide information directly to consumers in ways, which would
not be allowed through other media, such as the advertising of
Meanwhile, the advertising industry has largely failed to take
a responsible approach to the self-regulation of these new channels.
CA urges the Joint Committee to support further
co- rather than self-regulatory mechanisms for advertising. If
the government's objective is to achieve regulatory coherence
and coverage of new services, it follows that this principle should
apply to the converging advertising industry. OFCOM's powers should
enforce and ensure coherence in the regulation of advertising,
since consumers are unlikely to be aware of the different regulatory
standards and bodies when evaluating advertisers' claims. Improved
consumer representation is also central to moves towards extending
the co-regulation of advertising. The Consumer Panel will have
a key role to play in OFCOM's regulation of advertising, but CA
also expects the ASA to be one of the key external bodies to which
it should provide advice.
CA is unable to make detailed comments about
media ownership at this time. We would urge the Joint Committee
to consider what the proposed changes will mean for the viewer
as both citizen and consumer. Here it is important to distinguish
the consumer interest (which lies in maximising choice, value
and access) from the public interest (which relates to plurality,
diversity and democratic functions). We look forward to addressing
this issue in our full response to the draft Bill.
41 See CA research paper (2001) Turn on tune in
switch off: consumer attitudes to digital television and Which?
Online Annual Internet Survey (2001) The net result: evolution
not revolution. Back
See CA policy report (1997) Communications regulation: making
the right connections. Back
See Which? Online Annual Internet Survey (2001) The
net result: evolution not revolution. Back
See CA consultation response (2001) The Communications White
See NCC report (2002) Consumer representation: making it work.
See CA responses (2002) to the Cave review of spectrum management
and DCMS review of broadcast spectrum. Back
Compare BBC (2002) Governance in the OFCOM age with 18.104.22.168.
See CA response (1996) BBC charter debate. Back
See CA policy paper (1997) Self-regulation of advertising. Back
See CA policy report (2001) Promotion of prescription drugs:
public health or private profit? Back
See criticism of the ASA's Admark scheme in Computing Which?
(July 2001). Back