Lord Leveson has shown great interest in an Irish model of press regulation that allows for independence and accountability, but it may not be enough to tame Fleet Street.
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Ahead of the publication of Lord Leveson's report on Thursday one of the possible outcomes is an independent regulator with statutory backing, based on the system currently in place in Ireland.
An Irish-style press council is favoured by the National Union of Journalists (NUJ), according to the organisation's general secretary Michelle Stanistreet, who says regulation needs to be underpinned by a statute creating a body with clear terms of reference.
Ireland's system of press regulation was established in 2008 following years of debate over the country's difficult libel regime and plans to introduce tough privacy laws. The compromise was an independent press council and ombudsman tasked with safeguarding professional and ethical standards in print journalism.
How it works
The ombudsman enjoys statutory recognition and is tasked with taking complaints from members of the public and conciliating grievances to the satisfaction of all parties; where conciliation is not possible the ombudsman will make a ruling.
The press council is independent of the government and media, tasked with overseeing the code of practice for newspapers and magazines, and decides on appeals from the press ombudsman.
The council has 13 members; seven, including the chairman, are drawn from a "broad spectrum of Irish society", consisting of lawyers and academics. The remaining six represent the print industry, newspaper editors and the NUJ.
The code of practice enforced by the ombudsman aims to ensure reporting is true and accurate, comment is distinguished from fact and guarantees fairness, respect for rights and privacy. But while the ombudsman enforces privacy it also allows for people holding public office or seeking publicity to have their private lives probed where it is in the public interest.
Like the current PCC system Irish newspapers are not legally obliged to be regulated by the council, but publications that opt out face difficulties handling legal complaints. In April 2010 the press council was formally recognised under section 44 of the Defamation Act 2009, for the introduction of a fair and reasonable publication defence. Judges can now take into account co-operation with the council.
They have no power to initiate their own inquiry or even to examine or report on patterns of press misbehaviour
Noel Whelan, political commentator
Professor John Horgan, the current press ombudsman, is a former Labour politician who served in the Senate and the Dáil (Irish parliament) before becoming a professor of journalism at Dublin City University.
Mr Horgan told the Leveson inquiry that independence from the press, government and executive powers is vital for any regulator. He explained that every major newspaper in Ireland has been the subject of "critical adverse findings in one form or another" by his office.
"The sanction that we operate, which is the requirement to publish in certain modalities any decision upholding a complaint against them, is taken extremely seriously by the editors of all our publications.
"The public may not see it as seriously as they do, but in my experience, editors take it extremely seriously and would take considerable steps to avoid finding themselves in that situation."
However, not everyone agrees about the efficiency of the model. Irish Times political commentator Noel Whelan has recently claimed the press council is dominated by the industry and does not work.
Writing in the Irish Times he highlighted problems with journalists intruding on bereaved families: "The Ombudsman and council are neutered because they can only act when victims themselves complain.
"They have no power to initiate their own inquiry or even to examine or report on patterns of press misbehaviour."
Following the publication of topless pictures of Kate Middleton in the Irish Daily Star, Justice Minister Alan Shatter is now considering revisiting the planned 2006 Privacy Bill.
The threat of a privacy bill was first introduced by then Justice Minister Michael McDowell, of the now defunct Progressive Democrats. The prospect of privacy legislation and state regulation was enough to convince most editors to agree to an ombudsman solution.
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