PPA consultation responses and evidence from July 2007 are listed below in chronological order. For further information about these documents or older consultations please contact PPA Legal Director David Hyams.

PPA response to Ofcom/Atvod consultation on the setting of regulatory fees for video on demand services for the period up to 31 March 2011

May 2010

PPA has outlined to Ofcom its opposition to proposals for a flat-rate regulatory fee for providers of video-on-demand (VOD) services.

PPA response to IPO consultation on Taking Forward the Gowers Review of Intellectual Property

Mar 2010

PPA has given its support to proposals from the Intellectual Property Office (IPO) to extend certain copyright exceptions. The plans are outlined in a second stage IPO consultation, which was prompted by the Government as part of the implementation of recommendations from the Gowers Review in 2006.

Click here for the consultation document.

Click here for PPA's response to the first stage consultation in 2008.

PPA response to DCMS consultation on the digital extension to legal deposit 

Mar 2010

PPA has underlined the importance of protecting content creators’ intellectual property in response to a Department for Culture, Media and Sport (DCMS) consultation. The review is considering the extension of legal obligations that require publishers to provide copies of published print publications to the British Library and other deposit libraries for preservation purposes to digital publications.

PPA response to Ministry of Justice consultation on defamation action fees 

Feb 2010

The PPA has welcomed a decision by the Ministry of Justice (MoJ) to limit uplift fees in ‘no win, no fee’ defamation actions. The ruling by Justice Secretary Jack Straw follows a consultation on the issue. The PPA response is available above and the Media Lawyers Association's response is available here.

PPA response to DCMS consultation on libraries: Empower, Inform, Enrich - The Modernisation Review of Public Libraries

Jan 2010

PPA responded to the DCMS consultation highlighting that libraries should not be operating services in competition with, or in substitution for, those provided by publishers in the online world. If libraries are to become the route to "finding" a digital edition it is vital that they are not able to provide access on a "free" basis or basis which unfairly competes with publishers, certainly in the case of remote access to the library. 

PPA response to EC consultation on Creative Content in the European Digital Single Market 

Jan 2010

PPA has reiterated the importance of protecting the copyright of magazine and business media publishers' online operations in response to a recent European Commission reflection document. While the EC consultation on creative content online is designed to encourage the growth of vibrant online markets for goods and services protected by intellectual property rights, PPA is concerned that proposals, such as further harmonisation of copyright laws, could result in publishers having less control over how they monetise their content.

PPA response to Ministry of Justice consultation on Knowing or Reckless use of Personal Data

Jan 2010

PPA contributed to a cross-industry submission to this consultation, joining with other leading press associations to reject proposals for custodial sentences for breaches of section 55 of the Data Protection Act. PPA said the risk to press freedom coupled with the fact that prosecutions for breaches of section 55 are decreasing means that the introduction of prison sentences would be disproportionate and unjustified.

PPA response to the Press Complaints Commission Governance Review

Jan 2010

PPA responded to the review to highlight the magazine industry's commitment to effective self-regulation through the Editors Code of Practice and the jurisdiction of the independent PCC.

PPA response to the BIS consultation on Objecting to a Registered Office

Jan 2010

PPA responded to the Department for Business, Innovation and Skills consultation on Objecting to a Registered Office under the Companies Act 2006. PPA focused on the associated problem of rogue companies using names confusingly similar to well known companies (including several magazine publishers) in order to commit fraud. PPA has highlighted this problem to BIS on a number of occasions, but as yet no action has been taken.

PPA response to OFT Advertising and Pricing Market Studies

Dec 2009

In October 2009, the Office of Fair Trading launched studies into the online targeting of advertising and pricing. The studies cover behavioural advertising and customised pricing, where prices are individually tailored using information collected about a consumer's internet use. In its response, PPA maintained that online behavioural advertising is important for publishers to be able to serve relevant advertising to consumers and is an important factor in the generation of revenues that support quality online content and services.

PPA response to Ministry of Justice consultation on Defamation and the Internet: the Multiple Publication Rule

Dec 2009

PPA responded to the Government's consultation on the "multiple publication rule" - where each new publication of an allegedly defamatory article gives rise to a fresh cause of action. PPA called for a "single publication rule" which would mean that the time period within which an action for defamation must be commenced would be linked to the first time the defamatory item was published, distributed or accessed - and would not start a fresh with each distribution or access.

PPA response to EC consultation on the Legal Framework for Fundamental Rights to Protection of Personal Data

Dec 2009

PPA responded to the European Commission (EC) consultation on the legal framework governing the protection of personal data in light of developments in technology and the trend towards globalisation. PPA expressed the view that the existing framework was appropriate to protect individuals and businesses, and that the EC should focus any activity on ensuring regulatory harmonisation, improving enforcement and educating consumers.

PPA response to Ofcom Consultation on Proposals for the regulation of video on demand services

31st Oct 2009

PPA responded to the Ofcom consultation concerning the regulation of video on demand (VOD) services - expressing concern that audiovisual material on magazine and business publisher’s websites may be caught by new regulations, despite this not being the intention of the underlying European legislation, the Audiovisual Media Services Directive (AVMS). AVMS must be implemented by the government by the 19 December 2009. It is important for members to be aware of the new law as it requires VOD providers to register with a new co-regulator and pay a fee. Guidance on the scope of VOD services caught by the new law (which forms part of the current consultation) is due to be published.

The original consultation (September 2009)

PPA response to IPO Consultation on Assertion on Moral Rights

30th Sept 2009

Following calls by certain creators, the UK Intellectual Property Office (IPO) is looking into the issue of moral rights – ie the right of a journalist or photographer (or similar) to be identified as the creator; and the right of that creator not to have his/her work treated in a derogatory way. Currently, creators have to assert their moral rights, but there are calls to make moral rights apply automatically. PPA responded to an IPO consultation to point out that a change to the system could result in significant practical and administrative burdens for magazine and business media publishers.

PPA response to BIS Consultation on Legislation to Address Illicit Peer-to-Peer file-sharing

29th Sept 2009

The issue of Peer-to-Peer (P2P) file-sharing and online copyright infringement has regularly been in the news over the past couple of years. Headlines have been dominated by claims that individuals will have their internet access ‘cut off’ – and the music and film industries have clearly been the most vocal in this debate (as they have suffered the most damage). However, the issue of illicit sharing of copyright content online is one that is increasingly affecting magazine publishers. PPA responded to the BIS consultation above to stress that technical measures are a legitimate and proportionate way to tackle repeat infringers who ignore warning letters – and that account suspension must remain a possibility in the most extreme circumstances (subject to suitable safeguards), as P2P file-sharing is an increasing threat to PPA members who are developing sophisticated content access models.

Other relevant documents:

BIS Digital Britain Implementation Plan

13 Aug 2009

BIS has published a document setting out the various projects and measures that make up delivery of the actions set out in the Digital Britain report.

Joint response published in response to DG Sanco non-paper on behavioural advertising 

03 Aug 2009

EACA, ENPA, FAEP, EPC, FEDMA, IAB Europe and WFA joint response to DG Sanco’s non-paper on consumer related aspects of behavioural advertising of 5 March 2009.

PPA response to Creative Industries Review Group

06 Jul 2009

PPA response to the list of questions asked by the Conservative Party's Creative Industries Review Group. The consultation questions are contained in the response document.

PPA response to IPO Copyright Tribunal Consultation

30 June 2009

PPA supported the Confederation for British Industry’s response to the IPO Copyright Tribunal Consultation.

Digital Britain: Key points for magazine publishers

18 Jun 2009

PPA has summarised the main areas of the Digital Britain report that affect magazine publishers, namely orphan works, peer-to-peer file sharing, matched penalties for IP infringement, the proposed 'digital test bed' and education.

Strategic Advisory Board for Intellectual Property Policy (SABIP)

02 Jun 2009

PPA response to SABIP's 'Strategic Priorities for Copyright'

All Party Parliamentary Group on Communications Inquiry 'Can We Keep Our Hands Off The Net?'

27 May 2009

PPA response to All Party Parliamentary Group on Communications Inquiry 'Can We Keep Our Hands Off the Net?', 22 May 2009. The consultation questions are contained in the response document.

OFT Review of the Local and Regional Media Merger Regime Discussion Paper

31 Mar 2009

PPA response to the Office of Fair Trading Review of the Local and Regional Media Merger Regime.

Additional relevant documents:

Digital Britain

PPA response to Lord Carter’s Interim Report on 'Digital Britain'.

12 Mar 2009

PPA response to Lord Carter’s proposals to safeguard and promote Britain’s digital knowledge economy.

PPA contributed to the Publishers’ Content Forum response to the Digital Britain 'What Role for a Digital Rights Agency'. View the consultation document here.

Copyright Licensing Agency response

Additional relevant documents:

PPA response to 'Copyright the Future'

23 Feb 2009

PPA responded to the UK Intellectual Property Office consultation paper 'Copyright the Future: Developing a Copyright Agenda for the 21st Century'.

PPA response to BERR Consultation on the Proposed Consumer Rights Directive

06 Feb 2009

PPA responded to the Department for Business, Enterprise & Regulatory Reform (BERR) consultation the Proposed EU Consumer Rights Directive.

Additional relevant documents:

Joint response to DCMS Select Committee inquiry into Press Standards, Privacy and Libel

14 Jan 2009

PPA submitted a joint response to the DCMS Select Committee inquiry into Press Standards, Privacy and Libel on behalf of the Press Standards Board of Finance Limited, Newspaper Publishers Association, Newspaper Society, Periodical Publishers Association, Scottish Daily Newspaper Society and Scottish Newspaper Publishers Association.

PPA response to the Treasury Committee Inquiry into the Banking Crisis

06 Jan 2009

PPA responded to the Treasury Select Committee Inquiry into the Banking Crisis.

Further information on the Treasury Select Committee Inquiry is available here.

PPA response to 'Copyright in the Knowledge Economy'

28 Nov 2008

PPA response to the European Commission Green Paper on Copyright in the Knowledge Economy.

PPA response to DCMS Consultation on the Implementation of the Audiovisual Media Services Directive into UK Law

31 Oct 2008

PPA response to the first part of a two stage consultation process on the implementation of the Audiovisual Media Services Directive 2007/65/EC into UK Law, held by the Department for Culture, Media and Sport.

PPA response to UKIPO Consultation on Penalties for Copyright Infringement

31 Oct 2008

PPA response to the UK Intellectual Property Office consultation paper Taking Forward the Gowers Review of Intellectual Property - Penalties for Copyright Infringement.

PPA response to the BERR Consultation on Peer-to-Peer File-sharing

29 Oct 2008

PPA response to the Department for Business Enterprise & Regulatory Reform Consultation on Legislative Options to Address Illicit Peer-To-Peer File-sharing.

PPA response to House of Lords inquiry into the Implementation of Sir Bob Phillis' 2004 Review of Government Communications

15 Sep 2008

PPA response to Sir Bob Phillis' Independent Review of Government Communications presented to the Minister for the Cabinet Office January 2004.

OFT Consultation on Mergers - Jurisdictional and Procedural Guidance

20 Jun 2008

PPA letter responding to the Office of Fair Trading draft guidance consultation on 'Mergers - jurisdictional and procedural guidance'.

Taking forward the Gowers Review of Intellectual Property

07 Apr 2008

PPA responded to the UK Intellectual Property Office consultation on 'Proposed Changes to Copyright Exceptions'.

PPA response to the Commission Communication on Creative Content Online

29 Feb 2008

PPA responded to the Commission’s Communication on 'Creative Content Online in the Single Market'.

FAEP response to the Commission Communication on Creative Content Online

29 Feb 2008

In addition to its own submission, PPA provided input to the European Federation of Magazine Publishers' (FAEP) submission.

PPA joint response to review of the "30 Year Rule"

27 Feb 2008

PPA submitted a joint response with the Newspaper Publishers Association, the Newspaper Society, the Society of Editors, the Scottish Daily Newspaper Society and ITN to the independent '30 Year Rule' consultation.

More information is available here. The Final Report document is available here.

Joint response to consultation into Sharing of Personal Information in the Public and Private Sectors

15 Feb 2008

Joint response from PPA, the Newspaper Publishers Association, the Newspaper Society, the Society of Editors, the Scottish Daily Newspaper Society and ITN to the Ministry of Justice Data Sharing Review consultation.

PPA joint response with AOP to Culture Media and Sport Committee Inquiry 'Harmful Content on the Internet and in Video Games'

30 Jan 2008

Joint response from PPA and AOP to the DCMS inquiry into Harmful Content on the Internet and in Video Games.

Response to the Byron Review - Online content and protection of minors

30 Nov 2007

This response gives the opinion of PPA members for industry matters and also uses the results of informal research undertaken by a group of 6th form students of their peers’ (aged 12-15) on attitudes to media use to provide some background to its submission. The students will be making a separate submission to the ‘children and young people’s’ version of this consultation.

The full report of the Byron review is available here.

FAEP letter to the European Parliament Environment committee concerning the Chris Davies report on the community strategy to reduce CO² emission from passenger cars and light-commercial vehicles

28 Aug 2007

The European Federation of Magazine Publishers (FAEP) wrote to express concern over potential restrictions on advertising cars.

PPA response to Supplementary Paper: Consultation on the Draft Freedom of Information and Data Protection (Appropriate Limit and Fees Regulations) 2007

16 Jul 2007

The Government decided to issue a supplementary consultation on proposed changes to the Freedom of Information Act. PPA's position remains unchanged, in that changes are unnecessary.