That's right. I think it matters, when you think about self-regulation in practice, who is involved in setting up and designing the overall structure. I'm glad you mentioned the co-authors, Manuel Puppis and Sally Broughton. Manual's research, on which this is based -- it would be in German if we hadn't done this. He simply looks at press councils and analyses them according to a very simple framework, and finds that the UK system is really an outlier because of this basic structural feature.
Successful press councils tend to involve representatives not only of owners/publishers but representatives of journalist associations and journalist unions. That's the normal model. Whereas in the UK, we see that the founding of the self-regulatory body was wholly led by publishers.