Hacked Off have submitted a detailed response, backed by media academics, regulatory experts and individuals personally affected by press abuse, to the independent Press Recognition Panel's recent public consultation which closed Friday July 31st. The consultation asked how the Panel should apply Leveson's tests of independence and effectiveness to newspaper regulators who put themselves forward for "Recognition" under the Royal Charter system.Hacked Off's response was backed by many members of the public, who engaged with the Consultation process and either attended one of the Panel's public events or wrote in themselves to give their views.Hacked Off's submission (in three parts) is below. It was accompanied by the following letter to David Wolfe QC, Chair of the Recognition Panel.David Wolfe QC Chair, Press Recognition Panel107-111 Fleet StreetLondonEC4A 2AB

Date 31st July 2015

Dear DavidPlease find with this letter the Hacked Off submission to the PRP consultation on your proposals for receiving and determining applications for recognition from Regulators.We would like to thank you for your work to date and congratulate you on a clear consultation document with plenty of valuable and relevant proposals. By the nature of these responses they focus on areas of disagreement with the proposals, but that should not disguise the large areas of agreement. But a consultation is designed to seek views and improvements and we hope we have provided some.As you know Hacked Off was set up to campaign for an Inquiry into press ethics and then campaigned to have Parliament accept the Leveson recommendations and deliver a framework for the implementation of the Leveson reforms. We now campaign for full implementation of the Leveson reforms via the Royal Charter and the associated legislation, and if necessary by further legislation.We work with and behalf of many victims of press abuse including those who have successfully complained to the PCC, and the rather larger number who have tried and failed to get a fair hearing of their complaints at the PCC and at its successor body, IPSO.Between ourselves and our colleagues at the Media Standards Trust we have perhaps the deepest knowledge of any organisation about the serial failings of press regulation and in particular the failure to provide a fair and effective complaints system, and the way that the press industry prevents independent appointment and independent function of any regulator it sets up.We have sought to apply that knowledge and experience to this consultation response.We attended every day that the Leveson Inquiry covered forms of press regulation and read all the evidence. Following the publication of the Leveson Report, we “sponsored” its recommendations through to the Royal Charter to ensure they were not diluted or selectively transferred. This has given us an insight both into what the recommendations were seeking to achieve and – just as important – why they only went as far as they did.So we have we believe a unique insight into the background and purpose of the Charter criteria and recognition process, both from an analytical/academic point of view and from the point of view of victims, newspaper readers and the public (we have 80,000 registered supporters).In the run up to the Consultation we attended most of the PRP’s open Board meetings and we engaged with the PRP prior to the consultation in the stakeholder meetings. We attended many of the consultation meetings you held and encouraged our supporters to do so. We also met with you to discuss our views on your document.Following feedback from all these sources, and following consultations with the victims and experts that we work with, we put together this response.We also invited those of our supporters who wished to contribute to contact us so they would have a chance to read the consultation, our response and if they agreed with it to send it in under their own steam. A number of our supporters may have done this. We deliberately did not ask thousands to write in “form letters” but only those who volunteered at an earlier stage and would be able to read the documents in time.This is the extensive background to our response which I hope is reflected in its contents and in the way you and colleagues consider it.If you require clarification of any points please let us know and we will be pleased to provide more information publicly.We hope it is helpful.Yours sincerelyDr Evan Harris Joint Executive Director, Hacked OffNathan Sparkes Policy Manager, Hacked OffPlease find below links to three components of our response to the PRP consultation on how it will apply the Royal Charter criteria in respect of applications for recognition.Please note that these are drafts until midnight July 31st. They may change in minor ways.1. The questionsThe consultation document asks six questions. Please find Hacked Off's answers here:Questions 1-62. Premature evidence examplesThere are several evidence examples which are premature for initial applications for Recognition. Please find them with comments here:Examples of evidence inappropriate for initial recognition3. The matrixPlease find Hacked Off's detailed comments on the criteria matrix here:Matrix