The UK Media Law Pocketbook Second Edition 30th November 2022
By Tim Crook
The Official Secrets Act and the threat of prosecution to journalists and others gathering information about security and intelligence stories.
The policy of UK governments to deter security and intelligence sources with aggressive prosecution and aggressive policing applied to journalists receiving information.
The difficulties of releasing information through court proceedings and the campaign by executive bodies to establish secret hearings. Anonymity provisions for terrorist suspects through SIAC hearings.
The more helpful and effective brokering of national security advice through the Defence and Security Media Advisory Committee secretary
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Video-cast on Secret World and Media Law
8.0 Six bullet points summarizing key laws and concepts affecting the media when covering the secret world
8.1 Official Secrets Act risks
Online Links Printed Book
Pages 208 and 209
UK Official Secrets Act 1989
https://www.legislation.gov.uk/ukpga/1989/6/contents
Derek Pasquill was alleged to have breached the OSA by leaking letters and memos about the government’s attitude to secret Central Intelligence Agency (CIA) rendition flights and contacts with Muslim groups.
https://www.theguardian.com/media/2008/jan/10/pressandpublishing.medialaw
Katharine Gun leaked an email about spying on UN diplomats before the UK US invasion of Iraq in 2003.
https://www.guardian.co.uk/politics/2004/feb/26/interviews.iraq
‘Truth Matters’ Official Secrets – what is the true story behind the Keira Knightley film (Official Secrets)?
https://www.thesun.co.uk/news/10167643/official-secrets-what-is-the-true-story-behind-the-keira-knightley-film/
Law Lords’ rejection of David Shayler’s application for public interest and necessity defence. Shayler, R v [2002] UKHL 11 (21st March, 2002)
https://www.bailii.org/uk/cases/UKHL/2002/11.html
Court of Appeal sustaining reporting ban on contents of memo leaked in OSA prosecution
Times Newspapers Ltd & Ors v R [2007] EWCA Crim 1925 (30 July 2007) https://www.bailii.org/ew/cases/EWCA/Crim/2007/1925.html
House of Commons Library briefing on The Official Secrets Act and Official Secrecy 2017
https://commonslibrary.parliament.uk/research-briefings/cbp-7422/
Reforms to UK’s antiquated spying laws published by Law Commission 1 September 2020
https://www.lawcom.gov.uk/reforms-to-uks-antiquated-spying-laws-published-by-law-commission/
Home Office consultation on Legislation to counter state threats
https://www.gov.uk/government/consultations/legislation-to-counter-state-threats
Legislation to Counter State Threats (Hostile State Activity) Government Consultation document
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/986013/Consultation_Document_-_Legislation_to_Counter_State_Threats.pdf
OBSERVER AND GUARDIAN v. THE UNITED KINGDOM – 13585/88 [1991] ECHR 49 (26 November 1991)
https://www.bailii.org/eu/cases/ECHR/1991/49.html
THE SUNDAY TIMES v. THE UNITED KINGDOM (No. 2) – 13166/87 [1991] ECHR 50 (26 November 1991)
https://www.bailii.org/eu/cases/ECHR/1991/50.html
HM Attorney General for England And Wales v British Broadcasting Corporation (BBC) [2022] EWHC 380 (QB) (22 February 2022)
https://www.bailii.org/ew/cases/EWHC/QB/2022/380.html
Her Majesty’s Attorney General for England and Wales v British Broadcasting Corporation [2022] EWHC 826 (QB) (07 April 2022)
https://www.bailii.org/ew/cases/EWHC/QB/2022/826.html
HM Attorney General for England And Wales v British Broadcasting Corporation (BBC) (No. 3) [2022] EWHC 1189 (QB) (18 May 2022)
https://www.bailii.org/ew/cases/EWHC/QB/2022/1189.html
BBC News ‘MI5 agent used secret status to terrorise girlfriend.’
https://www.bbc.co.uk/news/uk-61508520
8.2 How the British state fights tooth and nail to keep embarrassing intelligence matters secret and legal proceedings relating to suspect terrorists are smothered in restrictions
Online Links Printed Book
Pages 212 and 213
Mohamed, R (on the application of) v Secretary of State for Foreign & Commonwealth Affairs [2010] EWCA Civ 65 (10 February 2010) https://www.bailii.org/ew/cases/EWCA/Civ/2010/65.html
Guardian News and Media Ltd & Ors, Re HM Treasury v Ahmed & Ors [2010] UKSC 1 (27 January 2010)
https://www.bailii.org/uk/cases/UKSC/2010/1.html
Secretary of State for the Home Department v AP (No. 2) [2010] UKSC 26 (23 June 2010)
https://www.bailii.org/uk/cases/UKSC/2010/26.html
SIAC anonymity provision rule 39(5)(h)
https://www.legislation.gov.uk/uksi/2003/1034/made
Justice and Security Act 2013. Sections 6 to 14 Closed material procedure: general
https://www.legislation.gov.uk/ukpga/2013/18/part/2/crossheading/closed-material-procedure-general
Statutory right of appeal against reporting restrictions and exclusion of media in relation to trials on indictment (Crown Court cases) https://www.legislation.gov.uk/ukpga/1988/33/section/159
Part 40 Criminal Procedure Rules 2020 Appeal to the Court of Appeal about reporting or public access restriction.
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/975241/crim-proc-rules-2020-part-40.doc
Successful appeal against holding bail applications in the Crown Court in chambers: Malik v Central Criminal Court & Anor [2006] EWHC 1539 (Admin) (27 June 2006) https://www.bailii.org/ew/cases/EWHC/Admin/2006/1539.html
Unsuccessful challenge to appeal decision without a hearing to hold part of a trial in camera: A & Ors, R v [2006] EWCA Crim 4 (13 January 2006) https://www.bailii.org/ew/cases/EWCA/Crim/2006/4.html
Influential open justice precedent: Scott & Anor v Scott [1913] UKHL 2 (5 May 1913)
https://www.bailii.org/uk/cases/UKHL/1913/2.html
Section 8(4) Official Secrets Act 1920
https://www.legislation.gov.uk/ukpga/Geo5/10-11/75/section/8
Successful appeal against ‘closed material procedure’ during civil litigation: Al Rawi & Ors v The Security Service & Ors [2011] UKSC 34 (13 July 2011)
https://www.bailii.org/cgi-bin/format.cgi?doc=/uk/cases/UKSC/2011/34.html
Challenge to orders by Mr Justice Nicol in Old Bailey terrorism trial of AB and CD in 2014
Guardian News And Media Ltd v Incedal & Anor [2014] EWCA Crim 1861 (24 September 2014)
https://www.bailii.org/ew/cases/EWCA/Crim/2014/1861.html
Challenge to be able to report the secret parts of the Old Bailey terrorism trial attended by accredited reporters in 2015.
Guardian News And Media Ltd & Ors v R. & Incedal [2016] EWCA Crim 11 (09 February 2016)
https://www.bailii.org/ew/cases/EWCA/Crim/2016/11.html
8.3 Defence and security media advisory (DSMA) Committee
Online Links Printed Book
Page 214
Defence and Security Media Advisory (DSMA) Committee
https://www.dsma.uk/
DSMA Standing Notices
https://www.dsma.uk/standing-notices/
BBC Editorial Guidelines Section 11 War, Terror and Emergencies
https://www.bbc.com/editorialguidelines/guidelines/war-terror-emergencies/
8.4 Updates and stop press
A downloadable sound file updating developments in relation to media law and state security
Replacement of Official Secrets Acts and new criminal offences for obtaining and disclosing official information beneficial to a foreign power
Many of the Official Secrets Acts have been replaced with a new National Security Act which had been proceeding through the UK’s Westminster Parliament during 2022 and 2023. It received Royal Assent 11th July 2023.
See: https://www.gov.uk/government/publications/national-security-bill-factsheets/espionage-etc-national-security-bill-factsheet and https://bills.parliament.uk/bills/3154
Professional journalism and journalism industry bodies had been very concerned about the lack of safeguards and defences for public interest journalists’ sources and any criminal liability applying to journalists receiving official information and reporting it in the public interest.
40 media organisations throughout the world signed a letter in January 2023 protesting that the Bill contained broad and vague definitions ‘that we believe will, even if unintentionally, impact on legitimate whistleblowers and public interest journalism.’ See: https://newsmediauk.org/blog/2023/01/11/global-media-warns-of-serious-concerns-with-national-security-bill/
The UK’s News Media Association (NMA) continued to press its concerns during the House of Lords Report Stage of the Bill’s passage through Parliament. See: https://newsmediauk.org/topics/national-security-bill/
On February 23rd 2023 it remained cautious in its reception of government proposals to table amendments to the National Security Bill which sought to address concerns around press freedom. See: https://newsmediauk.org/blog/2023/02/23/nma-comments-on-amendments-to-national-security-bill/
By way of background, journalism history in the 20th century recognises that broad and vaguely defined criminal offences legislated to tackle espionage without any public interest defences passed in 1911, 1920, 1939 and 1989 led to clumsy and oppressive prosecution of journalists and their sources over stories which were merely embarrassing politically to executive government and did not present any material risk to the interests of national security.
See the House of Commons Briefing Paper The Official Secrets Acts and Official Secrecy https://researchbriefings.files.parliament.uk/documents/CBP-7422/CBP-7422.pdf
See: ‘Amendments laid to strengthen National Security Bill The government has put forward its proposed amendments to the National Security Bill ahead of the Lord’s report stage.’ https://www.gov.uk/government/news/amendments-laid-to-strengthen-national-security-bill
The background to the reform discussion process is that the Law Commission did recommend that new legislation provided a public interest defence for civilians, including journalists covering circumstances where the court finds that the disclosure, and manner of disclosure, was in the public interest.
This recommendation was not present in the Bill tabled by the government and it can be argued is not reflected in proposed amendments.
The Home Office had been advancing a ‘Journalistic freedoms: National Security Bill factsheet- Aims of the bill and the Law Commission’s recommendations’ which it updated when it became an Act of Parliament in July 2023. See: https://www.gov.uk/government/publications/national-security-bill-factsheets/journalistic-freedoms-national-security-bill-factsheet
The Home Office argued: ‘The offences in the National Security Act target harmful activity by states, not leaks, whistleblowing activity or public interest journalism. This is a sentiment echoed by the Law Commission in oral evidence to the Public Bill Committee who were clear that in their view the requirements of the offences take them outside of the realm of leaks and into the realm of espionage.’
The Home Office explained: ‘The bill does not target leaks or whistleblowing activity and it does not replace the Official Secrets Act 1989 (OSA 1989) – a distinct piece of legislation which deals with unauthorised disclosures by those within government of specific categories of national security information, as well as onward disclosure and failing to safeguard the information. It is not focused at hostile activity from foreign states.’
The Home Office said the Law Commission did not recommend a public interest defence for journalists in respect of the offences created in the new act because ‘During their oral evidence to the committee for this bill in the other place [meaning House of Lords], the LC were clear that, in their view, the requirements of the offences take them outside of the realm of leaks and into the realm of espionage.’
The government said they did not reform the OSA 1989 because: ‘Given its complexity, we were concerned that reform of OSA 1989 would distract from the government’s package of measures in this bill to counter state threats and delay us from providing law enforcement and the intelligence agencies with the tools that they need now to directly tackle these threats.’
The briefing asserted the act provides safeguards for confidential journalistic material when police use the search and seizure powers in the legislation.
The government further argues it changed the phrasing of the threshold of knowledge on the part of potential offenders to ensure that legitimate journalistic activity is out of scope.
Journalists ‘would not be caught if they acted unwittingly or where they did not have information from which it could be concluded that they should have known’ they were handling protected information ‘prejudicial to the safety or interests of the United Kingdom.’
The Sun newspaper’s investigative journalist Harry Cole wrote: ‘Home Office official joked I should be jailed for one of my scoops – under new law criminalising journalists, I could be.’ 24th February 2023 See: https://www.thesun.co.uk/news/21508975/new-law-jailing-journalists-harry-cole/
The National Security Act as it is on receiving Royal Assent 11th July 2023:
See: https://www.legislation.gov.uk/ukpga/2023/32/contents
Explanatory notes on the Act prepared by the Home Office”
See: https://www.legislation.gov.uk/ukpga/2023/32/notes/division/1/index.htm
Section 38 of the Act becomes the relevant statutory power to enable courts to exclude media and public from court proceedings in the interests of national security.
The government issued the following media release 11th July 2023 ‘National Security Bill becomes law. On 11 July, the National Security Bill became law after being passed by both Houses of Parliament and securing Royal Assent.’
See: https://www.gov.uk/government/news/national-security-bill-becomes-law–2
Security Minister Tom Tugendhat said: ‘The National Security Act overhauls our outdated espionage laws and will provide our law enforcement and intelligence agencies with new and updated tools to deter, detect and disrupt modern-day state threats. For the first time there is an offence of foreign interference, meaning it will now be illegal to engage in conduct that interferes with fundamental rights, such as voting and freedom of speech, that are essential to the UK’s democracy.
And the Director General of MI5, Ken McCallum said: ‘The National Security Act is a game changing update to our powers. We now have a modern set of laws to tackle today’s threats.’
The Home Office also issued a ‘National Security Act Factsheet.’
See: https://homeofficemedia.blog.gov.uk/2023/07/11/national-security-act-factsheet/
And the Law Commission seemed to be pleased with how the Government and Parliament had responded to its recommendations when scrutinising and amending the legislation. See: ‘Recommendations on espionage offences implemented in National Security Act 2023.’
It said they had made recommendations to ensure ‘the law governing espionage is fit to counter threats to the UK’s national security from foreign powers, and that only sufficiently culpable conduct is criminalised. These recommendations followed extensive consultation with stakeholders, such as the News Media Association and the UK Intelligence Community, as well as assessment of classified evidence.’
However, history has shown that legislation passed by Parliament to deal with espionage and national security threats does has a tendency to catch journalists and their sources where disclosure of information classified as secret is politically embarrassing to the government of the day and carries the weight of public interest.
A former SAS soldier has lost a judicial review bid over a challenge to ban him from publishing a book about his counter-terrorism actions in Nairobi Kenya which earned him a bravery award. 6th October 2023.
The hearing was heard in private on the grounds of national security. The decision for it to be held with the media and public excluded was taken by Mr Justice Peter Lane 8th June 2023.
See: CC, R (On the Application Of) v Secretary of State for Defence [2023] EWHC 1804 (Admin) (08 June 2023) at: https://www.bailii.org/ew/cases/EWHC/Admin/2023/1804.html
He said at paragraph 13 that if the hearing was in open court: ‘…I agree that matters would come into the public domain which would, in effect, make the proceedings a dead letter. I am also of the view that national security interests concerning UKSF [UK Special Forces] will play a prominent part in the hearing and that those matters should not be disclosed in open court. I also accept what Mr Sanders KC says, that the policy of neither confirm nor deny on the part of the defendant would be put at risk if the proceedings were held entirely in open.’
Following the full judicial review hearing held in private on 13th and 14th June Mrs Justice Steyn released a public ruling that the application for judicial review by Christian Craighead of the decision by the Secretary of State for Defence had been unsuccessful.
See: Craighead, R (On the Application Of) v The Secretary of State for Defence [2023] EWHC 2413 (Admin) (03 October 2023) at: https://www.bailii.org/cgi-bin/format.cgi?doc=/ew/cases/EWHC/Admin/2023/2413.html
The judge summarised the case in her introductory paragraphs 1 to 4:
‘1 The claimant is a former member of the United Kingdom Special Forces (‘UKSF’, also referred to as ‘the Group’). In accordance with the anonymity order made on 21 November 2022, I shall refer to him in this judgment by his pseudonym, “Christian Craighead.”. While serving in Kenya, in January 2019, Mr Craighead engaged in a counter-terrorist operation at the DusitD2 hotel complex in Nairobi (‘the Dusit Incident’). He was subsequently awarded the Conspicuous Gallantry Cross, an award which may be given to “all ranks of the services in recognition of an act (or acts) of conspicuous gallantry during operations against the enemy“. As the Ministry of Defence (‘MOD’) readily acknowledges, Mr Craighead served the UK with honour, and he is a valued and respected member of the wider UKSF community.
2 By this claim for judicial review, Mr Craighead challenges the Secretary of State’s refusal on 25 July 2022 to give him “express prior authority in writing” (‘EPAW’) to publish a memoir he has written which contains an account of his involvement in the Dusit Incident (‘the memoir’). The central issue is whether that refusal unlawfully interfered with Mr Craighead’s right to freedom of expression. The focus of the claim, and consequently of this judgment, has been on article 10 of the European Convention on Human Rights (‘the ECHR’). The jurisprudence in respect of that Convention right is substantially at one with the long-established common law right to freedom of expression: see R v Shayler [2002] UKHL 11, [2003] 1 AC 247, [21] (Lord Bingham); R (Lord Carlile) v Secretary of State for the Home Department [2014] UKSC 60, [2015] AC 945, [13] (Lord Sumption JSC).
3 The parties have taken a cooperative approach to this litigation, with the Secretary of State acknowledging that Mr Craighead has approached this matter appropriately first by seeking EPAW and then, as he is entitled to do, by challenging the refusal through these proceedings. Although the courts have considered, in a number of authorities relied on by the parties and discussed below, issues arising in circumstances where former members of UKSF or of the intelligence services have disclosed information without authorisation, this case appears to be the first in which a public law challenge to a refusal of authorisation has proceeded to a substantive hearing. (R (A) v Director of Establishments of the Security Service [2009] UKSC 12 [2010] 2 AC 1 concerned an analogous claim which was later transferred to the Investigatory Powers Tribunal – which has jurisdiction in connection with the security and intelligence services – but the proceedings were settled.)
4 Insofar as it is possible to do so, without damaging the interests of national security or defeating the object of the proceedings, I address the claim in this OPEN judgment. I am handing down, at the same time, a Confidential Schedule to this judgment containing additional reasoning which cannot be disclosed publicly. Both parties and their representatives have seen the full judgment, including the Confidential Schedule.’
This is a classic Article 10 freedom of expression versus interests of national security balancing act judicial exercise, and as the Judge mentioned the first of its kind where the special forces author has sought permission and clearance for publication.
At paragraph 21 Mrs Justice Steyn explained why secrecy attaches to the identity of serving and past serving special forces operatives and their knowledge of operations: ‘In order to fulfil their functions, UKSF must be able to operate covertly, often in extremely dangerous environments. As Eady J observed in Ministry of Defence v Griffin [2008] EWHC 1542 (QB) at [4]: “It is clear that much of the work is sensitive and requires that they operate secretly.” Successive UK governments have adopted a policy of not commenting on UKSF matters, otherwise known as an NCND (neither confirm nor deny) policy.’
Mr Craighead also signed a confidentiality agreement before joining.
At paragraph 149 the judge explained the MOD as defendant produced ‘three witnesses [who] have all given evidence as to the effect of authorisation to publish the memoir on cooperation with other states. I have addressed their evidence on this issue in the Confidential Schedule. Given their roles, expertise and considerable experience of engaging with the authorities and armed forces of friendly foreign states, and the rationality of their evidence on these issues, I consider that the assessments made by the defendant’s witnesses as to how other states would be likely to react to publication of the memoir have high evidential value and should be respected: see Lord Carlile, [70] (Lord Neuberger PSC). The claimant does not have such expertise or experience and his views as to how foreign states would be likely to react should be accorded little weight.’
In the end Mrs Justice Steyn said she had to judge if the MOD’s refusal to allow Christian Craighead to publish this matters turned on proportionality and justification in law:
And at paragraphs 150 to 155 she set out the conclusion of her ruling:
150 In my judgment, the Secretary of State has succeeded in demonstrating that the interference with the claimant’s article 10 rights entailed in refusing to authorise publication of his memoir was proportionate and justified. There was a clear rational connection between the decision and the important objectives underlying it. In article 10(2) terms, those objectives were protecting national security and protecting information received in confidence, but the significance of the latter objective in this case is that the purpose is, in essence, to protect lives and to protect national security. It is well established that the court should be slow to differ from the executive’s assessment of the importance of the objective pursued in a national security context. The DSF clearly attaches “vital” importance to those objectives. The third criterion, the “least restrictive means” test, requires that “the limitation of the protected right must be one that ‘it was reasonable for the legislature to impose’“; it does not call for a strict application which would permit of only one executive response to an objective that involved limiting a protected right: see Bank Mellat, [20] (Lord Sumption JSC), [75] (Lord Reed JSC). In my view, this criterion was clearly met.
151 In considering whether a fair balance has been struck, I have borne in mind the importance to Mr Craighead of being able to tell his story. I have weighed in the balance his understandable wish to provide “an insider’s account of how a young man with a difficult upbringing served his country and saved lives during the Incident” (CCWS4 §25). Although he acknowledges that his interest is, in part, financial (CCWS4 §27), he wants to be able to tell his story about the Dusit Incident which, as he says, he thinks “reflects well on the UKSF and well on me” (CCWS4 §§23-24). He considers it unfair that so many other people (including Mr Ryan, a former member of UKSF who served prior to the introduction of the contract) are able to comment on the footage and the publicly available information about the Dusit Incident, and yet he is prevented from saying anything about it (CCWS4 §24). I have also borne in mind that the claimant is willing to make amendments and that article 10 protects speech that offends. The weight to be given to the claimant’s wish to tell his story is, however, reduced by dint of the fact that he voluntarily entered into the contract (see paragraphs 109-112 above).
152 I also agree with Mr Johnston that the article 10 rights of third parties should not be ignored. The interests of the potential publisher, and the interests of members of the public in reading the memoir, should be weighed in the balance, in my view, even though they have not themselves brought claims.
153 In Lord Carlile, the decision impeded political communication with Members of Parliament and so was “at the top of the hierarchy of free speech” ([61] (Lord Neuberger PSC)). The speech in this case is not near the top of the hierarchy. Although I have no doubt that many members of the public would be interested to read the memoir, there is not a high public interest in the content of the memoir being imparted to the public. Nor do the interests of the publisher carry much weight in circumstances where they were aware prior to contracting with the claimant that the ability to publish was dependent on obtaining EPAW.
154 Although I give some weight to Mr Craighead’s wish to tell his story, I also bear in mind that he has not been prevented from publishing any information about his upbringing or life before he joined the armed forces, or about his service prior to joining UKSF, and he has been able to disclose that he was selected for and served in 22 SAS. During the hearing, the Secretary of State also clarified that the claimant is permitted to state, albeit only in bare terms, that he was involved in responding to the Dusit Incident. He has only been prevented from giving an account of an operation, the Dusit Incident, in which he engaged as a member of UKSF. The decision accords with the clear and consistent policy and practice of UKSF, and the contract he signed.
155 On the other side of the balance are the interests of the community reflected in the defendant’s evidence. Those community interests entail the protection of lives, the protection of national security, the maintenance of the morale and efficiency of UKSF and protecting relations with defence partners. On the evidence before me, the interests of the community substantially outweigh the claimant’s interest in publishing a memoir about the Dusit Incident (even when buttressed by the interest of the public in receiving the information he wishes to disclose, and by the interest of his publisher). I conclude that the decision did not breach the claimant’s article 10 rights.’
Journalism coverage of this case:
Mail Online 5th October 2023 “Former SAS soldier gagged from releasing his book on how he defeated Kenya’s Islamic terrorists because judge thinks it will expose forces’ tradecraft.”
Mail Online 5th May 2023 ‘SAS hero who earned global acclaim for saving hostages from jihadi terrorists in hotel siege fights Ministry of Defence gagging order that bans him talking about it.’ See: https://www.dailymail.co.uk/news/article-12051351/SAS-hero-fights-Ministry-Defence-gagging-order-bans-talking-it.html
Telegraph 4th October 2023 ‘Ex-SAS soldier loses court battle to lift ban on Kenyan terror attack book. Christian Craighead was awarded the conspicuous gallantry cross for fighting al-Shabaab terrorists at the Dusit D2 hotel in Nairobi in 2019.’ See: https://www.telegraph.co.uk/world-news/2023/10/04/ex-sas-loses-court-battle-lift-ban-book-kenya-terror-attack/
BBC News report on 2019 Nairobi hotel siege. ‘Kenya terror attack: What happened during the Nairobi hotel siege?’ 12 February 2019.
See BBC filmed report: https://www.bbc.co.uk/news/av/world-africa-47202313
Pdf file media law briefing on this topic
Secondary Media Law Codes and Guidelines
IPSO Editors’ Code of Practice in one page pdf document format https://www.ipso.co.uk/media/2032/ecop-2021-ipso-version-pdf.pdf
The Editors’ Codebook 144 pages pdf booklet 2023 edition https://www.editorscode.org.uk/downloads/codebook/codebook-2023.pdf
IMPRESS Standards Guidance and Code 72 page 2023 edition https://www.impress.press/wp-content/uploads/2023/02/Impress-Standards-Code.pdf
Ofcom Broadcasting Code Applicable from 1st January 2021 https://www.ofcom.org.uk/tv-radio-and-on-demand/broadcast-codes/broadcast-code Guidance briefings at https://www.ofcom.org.uk/tv-radio-and-on-demand/information-for-industry/guidance/programme-guidance
BBC Editorial Guidelines 2019 edition 220 page pdf http://downloads.bbc.co.uk/guidelines/editorialguidelines/pdfs/bbc-editorial-guidelines-whole-document.pdf Online https://www.bbc.com/editorialguidelines/guidelines
Office of Information Commissioner (ICO) Data Protection and Journalism Code of Practice 2023 41 page pdf https://ico.org.uk/media/for-organisations/documents/4025760/data-protection-and-journalism-code-202307.pdf and the accompanying reference notes or guidance 47 page pdf https://ico.org.uk/media/for-organisations/documents/4025761/data-protection-and-journalism-code-reference-notes-202307.pdf
UK Media Law Pocketbook Second Edition 