I'd be very happy to do that.

I think there is. I think there are several examples of cases where, although one should always look at the article, it doesn't provide a get-out-of-jail for a misleading headline. There's a case we've done very recently, which we'll publish shortly, on that point.

So I ...

Yeah, I do. I think that what we've done rather better recently is -- I actually think that it's the duty of the PCC to engage with groups like that.

If you look at the parallel case of, say, mental health reporting. That's where we've worked very ...

Yes.

Yes.

Yes.

I don't think it is because I think (a) it doesn't preclude a statutory model, because I think we can talk about -- I think it's really important for the newspaper industry that they don't just throw their hands up about statutory regulation the whole time. I ...

I don't think it is.

No, there are questions whether you can build in compensation arrangements, because in a contract you can't build in penalties, but you can build in compensation, but that would be difficult.

I think the bottom line with all of this is that if major players aren't willing to ...

Politically, and I think from a consumer perspective we shouldn't have to live with a big-player problem.

True, but if some people are carrot averse, and they decide not to do it, then if we can live with that, I suppose, is the question. But you're right, the more attractive that you make it, the less of a problem it would be.

I think that sort of incentivisation is very appropriate and should be strongly considered. I suppose the difficulty one has to come up with is if that incentivisation leads to every major newspaper player, some online sources that otherwise would be outside the system wanting to be members, a general ...

As with a carrot.

To my mind, that is how I see it. Now, the notion of compelling people to be a member is not one I can offer the perfect answer to.

No --

To me, I think you can go a long way with definitional clarity, and which can include greater teeth by saying -- that's why the two-pronged approach -- and leave aside the potential third prong, which I know you're interested in, to do with arbitral reactions to libel and privacy ...

I think what it would be able to do is you would still be able to offer swift redress to complaints. There would still be all the existing operations of the other authorities, but there would be an appropriate response after the event that would lead to standards changing -- punishment ...

That's possible, but if you're clear enough about it and you still have imposed a suitable sanction in respect of the complaint, then he or she, the complainant would have the advantage of whatever that sanction may be, or settlement even, but the systemic point would be addressed ...

I think the issue of sanctions to me has always been predicated on how you would introduce, say, fines into a fast-moving, complaints-handling system. I think the answer to that may be that you don't but if you were to be much more obvious in the future -- in a ...

I think some -- and to me there's a -- if a perception is sufficiently widely held, it is as significant as something that is real. So I don't wish to diminish something by merely saying it's a perception. People can do that and that diminishes the importance of ...

Sorry, my point is this: major players have to be involved. How does one conceive of a system which definitionally encompasses everyone who is performing a newspaper-like function? Private Eye's not a member of the system either. I don't think universality actually is possible in the new world ...

No, but I think one -- and this may not be a hugely helpful answer but either you believe that there is a prospect of universality of a system or you don't.

Now, to me personally, the advent of online, the number of people who look like they can be ...

Well, actually, my understanding -- Mr Desmond, I think, didn't want to pay the money, was the first thing that I ever heard about this and consistently heard about this. His objections, I think, were less to the PCC as to the -- and maybe this doesn't matter, but I ...

I think that the risk of legislation is that the course of legislation can lead to things being added and amended by the system of Parliament we have, and so there's a risk inherent in legislation because titles can be changed of bills and amendments can be made and ...

No, I don't think that's right. I think on the specific cases they have to be weighed properly. My mission is if you're thinking about a structure, one has to have regard for the nature of the industry itself, and I think that can't come at ...

No, I don't --

Yeah, I think there's two points there. One is the statutory point, which will be endlessly and rightly discussed, which is: if you versus a statutory involvement in the system, how far can you have that whilst still preserving freedom of expression?

Then there's the second point, which ...

I'm happy that we shouldn't use the term "regulator" to describe the PCC. I think it performs some functions that a regulator would. I think pre-publication intervention, having a code of practice, training, they are regulatory functions, but I'm -- that's why I don't believe it ...

Yes, and I think it's gone up to 13,00 and something in 2011.

Yes. We're excluding those. The overall turnover of all complaints in 2010, I think, was 17 days, but that includes all those which go at the first hurdle. The investigation is one where we've taken it up with the editor and are having an exchange with correspondence.

Yeah.

Yes.

It sounds -- I think I was getting carried away with my own rhetoric there. I think the practical and procedural are probably closely linked together. If people wish to make complaints, particularly members of the public, and we're not able to offer a service to them, that is a ...

That's right. The difference then was that we continued to consider complaints but that position had changed by 2010/2011.

Exactly.

Yeah.

Section 5, tab 34?

No, although I think the difficulty that exists is that if you're, say, an NGO or a charity, you can still say you have your own set of standards internally that you're following which still will allow you to avail yourself with Reynolds, but I suspect if you ...

But my understanding is the incentivisation is that if you are a member, you can have at least a shot at a Reynolds defence by saying you're a responsible journalist.

There's a Reynolds-type benefit, but to say -- I believe, and I don't want to hold myself out as an expert in this --

It is voluntary, yes, although it's incentivised, I believe, by the Defamation Act.

Actually in terms of structure, it is -- they used quite a lot of PCC expertise in terms of setting it up, so it is primarily a complaints-handling body. The ombudsman takes a lot of complaints. He refers them up if he thinks there's a breach of the code. That ...

A little bit. To my understanding, it is rather similar to the PCC, except for this two tier approach that it takes, and the fact that its existence is referenced in the Defamation Act, which I think is a significant factor to which you will no doubt refer, and I ...

That's right.

Yes.

My understanding would be that there is not another body. I know that the ombudsman in Sweden has an educational role in terms of training and promotional work, but there's a large extent to which that crosses over with the PCC as well. I don't believe that there ...

I think that -- my understanding is that they are -- no, they are primarily -- these are the bodies that exist in these countries, and they're primarily public-facing complaints bodies.

No, I think that they are considered to be primarily complaints-handling bodies.

Yes, the most notable example being Germany, which has a no-strings-attached grant from the government.

I do not know, I'm afraid. I could find out, but I don't know.