After the Press Complaints Commission chair, Lord Hunt, and its director, Michael McManus, struggled to answer MPs’ questions last month about the most complained-about newspapers, we published our own table based on the PCC’s own Monthly Complaint Summaries for 2013.Our analysis showed that at the top of the league table of complaints received by the PCC against national and Sunday newspaper titles was the Daily Mail with 36.4% of the total, followed by the Sun with 19.1%. The Mail on Sunday was the top weekly publication (with 5.0%).Our blog was reported by Press Gazette and by Professor Roy Greenslade in his The Guardian blog, where, in a long burst of irony, he addressed the idea that the PCC might be protecting these papers:

. . . I cannot imagine for a moment that Hunt and McManus did not compile the list shown above for that reason. These are not men in hock to Dacre, the Mail or The Sun.

They have inherited a system that has a history of failing to compose such a table. No previous PCC chairman or director saw fit to show which publications were responsible for generating the greatest number of complaints.

And none of them were in any way connected to the publishers of the Mail and Sun, the companies that contribute the largest sums to fund the PCC. Except, of course, in terms of their pay.

It would be wrong to imply that Lord Hunt (who is paid £180,000 for a three-day week by PressBoF) takes his pay into account when assembling statistical tables. I would guess that it just never occurred to him that the public might be rather interested in them.

Associated Newspapers (publishers of the Mail and Mail on Sunday) then denounced our figures as ‘a wildly inaccurate picture of the number of Daily Mail stories about which the PCC received valid complaints’.

They include complaints about stories which were never published in the Daily Mail but solely by Mail Online which, with 11 million daily readers, is the world's biggest newspaper website and generates more than 50% of its content entirely independently of the Daily Mail.

It is worth remembering here that we only published our table because the PCC has not done the job and because its director, Mr McManus, told MPs that all the necessary statistics were published and that the public was welcome to draw its own conclusions. (Although there have been repeated demands in recent years for the PCC to produce better statistics – including in the Leveson Report – nothing much has changed. The PCC, insists Mr McManus, is ‘not hiding anything’.)Looking at each aspect of the Associated complaint:1. It said our table of complaints did not distinguish between the Daily Mail and the Mail OnlineWe relied on the published PCC statistics and the PCC does not appear to separately record complaints about Mail Online. Unless the PCC asks them, only the Daily Mail could know which complaints relate to online-only stories. If the Mail thinks the distinction important it should insist that its figures are recorded separately from the Mail Online’s.If the Mail’s point here is that because it has a lot of readers it has a lot of complaints, separate figures for online and print would look better. And if that’s true, then surely the Mail’s response should be to make that point, not to try and bury the statistics.2. Our figures were “a wildly inaccurate picture of the number”Again, these are not our figures but the PCC’s, from their monthly summaries of total complaints.We accept that the figures are inaccurate in one important respect, because they are without doubt a substantial underestimate of the total complaints. For reasons unexplained, when there are multiple complaints about the same story the PCC includes them all if the number is small but includes none (or a handful) if the number is very large.Mr McManus was forced to admit that the PCC received over a thousand complaints about the Mail’s treatment of the late Ralph Miliband. How many featured in the monthly summaries? As far as we can tell, none.When the Mail monstered Lucy Meadows, the transgender teacher who committed suicide after weeks of press abuse, there were hundreds of PCC complaints, but only a handful appear in the monthly summaries.This in itself could be said to invalidate the headline figures in the PCC’s monthly summaries relating to total complaints and it probably explains why the totals in those summaries never tally with the PCC’s annual totals. No other public-facing complaints-handling organisation would tolerate such muddle over such a key measure, but the PCC is no ordinary body.3) “the number of Daily Mail stories” about which there were complaintsThe PCC figures make it very difficult for anyone to make accurate statements about the numbers of stories or articles that were complained about, and we made no such statement. We wrote about total numbers of complaints.The PCC monthly summaries do not aggregate the complaints by individual stories, nor do they provide dates for the stories or for the complaints. Further, some stories involve multiple breaches of the Editors’ Code (on accuracy, intrusion and discrimination, for example) or multiple breaches on under one heading (accuracy, for example). So counting complaints by story – even if the PCC were to do it – would still not give the full picture.Again, if the Mail would prefer to be judged by the number of its stories or articles that are complained about, perhaps it could persuade the PCC to publish those figures too.4) “…about which the PCC received valid complaints.”The blog did not claim that the totals we had gleaned from the PCC’s monthly summaries were the total of ‘valid’ complaints. And if you look at the summaries you would be forgiven for thinking there were almost no ‘valid’ complaints, because the PCC goes out of its way to avoid recording simple breaches of the Editors’ Code.According to the PCC rules, a complaint about a newspaper article isn’t deemed to be ‘valid’, and isn’t taken up with the publication, unless the PCC itself has reason to believe it involves a breach of the Editors’ Code.If the PCC isn’t happy with the newspaper’s response, the next stage is mediation, where the newspaper makes an offer of a correction, apology or some other remedy that may satisfy the complainant.If the complainant takes up the offer, which in most cases amounts to a guilty plea and remedy, then no breach is recorded against the newspaper – even though in most cases a breach is effectively admitted. These are breaches or ‘presumed’ breaches. In the remaining cases, where the paper takes some corrective action but does not admit a code breach, a code breach probably occurred. Why else would a paper take corrective action?Absurdly, the PCC only formally records that a newspaper has breached the Editor’s Code if the PCC Commission upholds an official adjudication – and fewer than 50 of those happen per year.So if mediation isn’t successful, then complainants, often with a blatantly obvious breach, must continue to battle on in a process often lasting months, or even years, to have any hope of obtaining an adjudication. If they get worn down and settle at any point, the investigation is closed and no breach is ever recorded.Even when there is a code breach, the PCC will not award an adjudication and record a code breach if it decides that the newspaper has made a satisfactory offer of remedy. This is called “Sufficient Remedial Action” (SRA), even when it may not be sufficient as far as the complainant is concerned. The PCC can decide this is the case at any stage (called an SRA) or in an adjudication (called an “Adjudication – SRA”).Associated objected to our table because it showed the Mail in a very bad light, but their problem is not with the table. It is with the facts. The table based on the PCC data, and the PCC said it was ‘not hiding anything’.If Associated is concerned that the PCC data is not fair to it, then it should demand that the PCC produce clearer material. What would the Daily Mail say if a banking regulator fudged its figures? Or a food regulator?