It's obviously a personal view born of experience, but I was for eight or nine years the Director General of the Advertising Standards Authority, which is an effective self-regulatory body. Of course, I can't speak for the ASA these days, I'm two and a half years out of it and there have been all sorts of changes in structure and so on. But I simply offer the view that I gave at the seminar, which preceded this stage of the Inquiry, and that is for self-regulation to be credible, it has to be effective, and it has to be so structured that the public can have confidence that those who are being regulated are not just looking after their own interests.
The difference between the Advertising Standards Authority and the Press Complaints Commission in my day was that there was a much greater separation of function between the investigatory and adjudicatory side, the Advertising Standards Authority, and the code writing side, the Committee of Advertising Practice and latterly the Broadcast Committee of Advertising Practice. A lay majority on the ASA council with the minority of experienced industry people not being the equivalent of serving editors.
I don't know whether it had always been that way with the ASA. When I came in in 2000, a number of the newspaper trade associations, who of course are part of the tripartite advertisers, agencies and media, were very concerned to explain to the new boy that I shouldn't be seeking to adjudicate all the time, it should be a word in the ear. The industry would follow the lead that the regulator gave; it didn't need to be done so publicly and so formally. And I disagreed. But I was told that I should look at the way that Lord Wakeham runs the Press Complaints Commission, and I think there may have been a bit of a parting of the ways there.
As an observer, and a friendly observer, I think it's a huge mistake to have serving editors serving on the Press Complaints Commission. I think the editors should write the code, and be prepared to be judged on the titles' observance of it, and then it's up to a demonstrably independent and effective Press Complaints Commission to apply that code. That was the model in the advertising standards business, that is widely respected, and it's something to which the media, the non-broadcast media, of course are involved in through their membership of the Committee of Advertising Practice, so I don't see why it's such a difficulty when it comes to the PCC.