Leveson Inquiry

The Information Commissioner's Office should take immediate steps to prepare, adopt and publish a policy on the exercise of its formal regulatory functions in order to ensure that the press complies with the legal requirements of the data protection regime.

The Inquiry asked the Information Commissioner's Office to publish a press regulation policy. In January 2013, it accepted the recommendation and stated that it was revising its Data Protection Regulatory Action Policy to address how it would regulate the press (Information Commissioner's Office response, Jan 2013). That statement described revising the policy, but did not mention adopting or publishing it (Information Commissioner's Office response, Jan 2013).

In discharge of its functions and duties to promote good practice in areas of public concern, the Information Commissioner's Office should take immediate steps, in consultation with the industry, to prepare and issue comprehensive good practice guidelines and advice on appropriate principles and standards to be observed by the press in the processing of personal data. This should be prepared and implemented within six months from the date of this Report.

The Inquiry asked the Information Commissioner's Office to publish data protection guidance for the press. In September 2014, it published guidance for the media explaining data protection obligations, clarifying journalism exemptions, and advising on good practice (Information Commissioner's Office, Sep 2014). It had previously reported in June 2013 that it had consulted on developing guidance for the press and on issuing it as a code of practice (Information Commissioner's Office, Jun 2013). In January 2013, it recognised the need to prepare guidance based on data protection law as it then stood and the importance of consultation with the press and broadcasting industry (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take steps to prepare and issue guidance to the public on their individual rights in relation to the obtaining and use by the press of their personal data, and how to exercise those rights.

The Inquiry asked the Information Commissioner's Office to publish public guidance on press data rights. In January 2013, it stated that it recognised the importance of developing this guidance and would publish it alongside a proposed code of practice, aiming to have it ready by the end of May 2013 (Information Commissioner's Office response, Jan 2013).

In particular, the Information Commissioner's Office should take immediate steps to publish advice aimed at individuals (data subjects) concerned that their data have or may have been processed by the press unlawfully or otherwise than in accordance with good practice.

The Inquiry asked the Information Commissioner's Office to publish advice on press data processing. In January 2013, it stated that it understood the importance of ensuring that individuals are aware of their rights if their data has been unlawfully processed by the press, but publishing advice was not mentioned in the source (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office, in the Annual Report to Parliament which it is required to make by virtue of section 52(1) of the Act, should include regular updates on the effectiveness of the foregoing measures, and on the culture, practices and ethics of the press in relation to the processing of personal data.

The Inquiry asked the Information Commissioner's Office (ICO) to report annually on press data practices. In January 2013, it stated that it accepted "the spirit of this recommendation" and would provide regular updates to Parliament on the effectiveness of its measures and on press culture, practices and ethics regarding personal data (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should immediately adopt the Guidelines for Prosecutors on assessing the public interest in cases affecting the media, issued by the Director of Public Prosecutions in September 2012.

The Inquiry asked the Information Commissioner's Office to adopt prosecution guidelines for media cases. The office stated in January 2013 that, by the time the Inquiry's report was published, it had already endorsed and adopted the September 2012 guidelines issued by the Director of Public Prosecutions on assessing public interest (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take immediate steps to engage with the Metropolitan Police on the preparation of a long-term strategy in relation to alleged media crime with a view to ensuring that the Office is well placed to fulfil any necessary role in this respect in the future, and in particular in the aftermath of Operations Weeting, Tuleta and Elveden.

The Inquiry asked the Information Commissioner's Office to agree a media crime strategy with police. In January 2013, it accepted the recommendation, explaining that it had begun engaging with the Metropolitan Police Service (MPS) and the Association of Chief Police Officers (ACPO) to establish formal policies, though it did not mention Operations Weeting, Tuleta or Elveden (Information Commissioner's Office response, Jan 2013). It stated that it would meet with the MPS in January 2013 to set out protocols and amend guidance (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take the opportunity to review the availability to it of specialist legal and practical knowledge of the application of the data protection regime to the press, and to any extent necessary address it.

The Inquiry asked the Information Commissioner to review specialist knowledge regarding the press. In January 2013, the Information Commissioner's Office stated that it had undertaken the review and recognised the need for more specialist knowledge of press workings and data protection, but addressing that need was not mentioned in the sources (Information Commissioner's Office response, Jan 2013).

The Information Commissioner's Office should take the opportunity to review its organisation and decision-making processes to ensure that large-scale issues, with both strategic and operational dimensions (including the relationship between the culture, practices and ethics of the press in relation to personal information on the one hand, and the application of the data protection regime to the press on the other) can be satisfactorily considered and addressed in the round.

The Inquiry asked the Information Commissioner's Office to review its organisation and decision-making processes. In January 2013, it stated that its management structure and controls were very different from those that existed during the events examined in detail by the Inquiry (Information Commissioner's Office response, Jan 2013). It explained in January 2013 that its current arrangements were designed to ensure that large-scale issues with both strategic and operational dimensions are properly considered and addressed in the round (Information Commissioner's Office response, Jan 2013). The record holds nothing dated later than the response of January 2013 (Information Commissioner's Office response, Jan 2013).

The Home Office should consider and, if necessary, consult upon: (a) whether paragraph 2(b) of Schedule 1 to the Police and Criminal Evidence Act 1984 (PACE) should be repealed; (b) whether PACE should be amended to provide a definition of the phrase "for the purposes of journalism" in s13(2); and (c) whether s11(3) of PACE should be amended by providing that journalistic material is only held in confidence for the PACE provisions if it is held or has continuously been held since it was first acquired or created subject to an enforceable or lawful undertaking, restriction or obligation.

The Inquiry asked the Home Office to consider amending statutory protections for journalistic material. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the department, stated that "All the recommendations have been addressed", though his answer did not mention the specific amendments to the Police and Criminal Evidence Act 1984 (PACE) (Lord Sharpe of Epsom, May 2024). Earlier, in February 2013, the department accepted the recommendation and announced that it would consult before the end of 2013 on proposed changes to PACE, including the protection of journalistic sources (Home Office response, Feb 2013; Home Office, Feb 2013).

Exemplary damages (whether so described or renamed as punitive damages) should be available for actions for breach of privacy, breach of confidence and similar media torts, as well as for libel and slander. The application to a defendant of any relevant system of regulation of standards enforcement which is contained in or recognised by statute and good internal governance in relation to the sourcing of stories should be relevant to the decisions reached in relation to such damages.

The Inquiry asked the UK Government to make exemplary damages available for media torts. In March 2018, the Department for Digital, Culture, Media and Sport stated that exemplary damages provisions in sections 34 to 38 of the Crime and Courts Act 2013 commenced in November 2015, exempting publishers in a recognised regulator from exemplary damages in relevant media-related court cases, though internal governance was not mentioned (Department for Digital, Culture, Media and Sport, Mar 2018). Prime Minister David Cameron had confirmed in March 2013 that the Government accepted the recommendation and would establish exemplary damages through legislation (David Cameron response, Mar 2013).

The term 'off-the-record briefing' should be discontinued. The term 'non-reportable briefing' should be used to cover a background briefing which is not to be reported, and the term 'embargoed briefing' should be used to cover a situation where the content of the briefing may be reported but not until a specified event or time. These terms more neutrally describe what are legitimate police and media interactions.

The Inquiry recommended that police replace off-the-record briefings with non-reportable or embargoed briefings. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that recommendations on the police and the press had been accepted by the National Police Chiefs' Council (NPCC) and were all addressed (Lord Sharpe of Epsom, May 2024). In October 2025, the College of Policing updated its media relations guidance, stating: "Avoid the term 'off the record' as the basis for a conversation" (College of Policing, Oct 2025).

It should be mandatory for ACPO rank officers to record all of their contact with the media, and for that record to be available publicly for transparency and audit purposes. This record need be no more than a very brief note to the effect that a conversation has taken place and the subject matter of that conversation. Where the discussion involves a more significant operational or organisational matter, then it may be sensible for a more detailed note to be retained. Finally, in circumstances where policy or organisation matters may be on the agenda for discussion, it is good practice for a press officer also to be present.

The Inquiry recommended that chief police officers publicly record all contact with the media. In a May 2024 written answer, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, relayed that the recommendation was accepted by the Association of Chief Police Officers, superseded by the National Police Chiefs’ Council (NPCC), and stated that "All the recommendations have been addressed" (Lord Sharpe of Epsom, May 2024). In Authorised Professional Practice updated in October 2025, the College of Policing stated that chief officers should publicly record all media contact where policing matters are discussed (College of Policing, Oct 2025).

The simple rule included within the 'Interim ACPO Guidance for Relationships with the Media' should be adopted as good practice. This is: "Police officers and staff should ask: 'am I the person responsible for communicating about this issue and is there a policing purpose for doing so?' If the answer to both parts of this question is 'yes', they should go ahead."

The Inquiry recommended adopting a simple rule to govern police contact with the media. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that recommendations on the press and the police had been accepted by the National Police Chiefs' Council (NPCC) and addressed (Lord Sharpe of Epsom, May 2024). In October 2025, the College of Policing published updated Authorised Professional Practice on media relations, confirming that officers and staff should communicate with journalists if they are responsible for the issue and have a policing purpose (College of Policing, Oct 2025).

The Police Service should re-examine the rigour of the auditing process and the frequency of the conduct of audits in relation to access to the Police National Computer (PNC). Additional consideration should also be given to the number of people given access to the PNC and the associated rules which govern its usage.

The Inquiry recommended reviewing Police National Computer access rules and audit rigour. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that policing recommendations accepted by the National Police Chiefs' Council had been addressed (Lord Sharpe of Epsom, May 2024). The Minister did not detail the auditing frequency or limits on the number of people granted access (Lord Sharpe of Epsom, May 2024). Earlier, in February 2013, the department reported that the Association of Chief Police Officers supported applying greater rigour to access audits, alongside a planned inspection of the system (Home Office, Feb 2013).

The recent ACPO Guidance should more specifically spell out the dangers of consuming alcohol in a setting of casual hospitality (without necessarily specifying a blanket ban).

The Inquiry asked police guidance to warn against alcohol consumption during casual hospitality. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that the recommendation was accepted by the then Association of Chief Police Officers (ACPO) and that all policing and press recommendations have been addressed, though the answer did not specifically mention alcohol guidance (Lord Sharpe of Epsom, May 2024). The department had previously reported in February 2013 that ACPO committed to reinforce its guidance on the consumption of alcohol at events (Home Office, Feb 2013).

Consideration should be given to the terms upon which ACPO rank officers are appointed and, in particular, whether these terms should include some limitation upon the nature of any employment within or by the media that can be undertaken without the approval of the relevant authority for a period of 12 months following the cessation of the appointment.

The Inquiry recommended considering 12-month post-employment media work restrictions for senior police officers. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated in a written answer that recommendations on the police and the press had been accepted by the government, the College of Policing, and the former Association of Chief Police Officers (ACPO), and that all had been addressed (Lord Sharpe of Epsom, May 2024). The department had accepted the recommendation in February 2013, noting that it would work on implementation with police and crime commissioners and ACPO (Home Office, Feb 2013).

An enhanced system for protection of whistleblowers and for providing assistance for the Police Service on general ethical issues should at least comprise the following: (a) greater prominence should be given to the Public Interest Disclosure Act (PIDA) telephone line operated by the Independent Police Complaints Commission (IPCC); (b) there should be an 'ethics line' to the IPCC, available for all serving Police Officers, providing general ethical guidance; (c) to avail those at rank of Chief Constable (Assistant Commissioner level within the Metropolitan Police Service), Her Majesty's Inspectorate of Constabulary should identify one of its members, a former Chief Constable, as the designated point of contact for confidential ethics guidance. The Chief Officer seeking and obtaining that advice would be able to refer to it should any issue subsequently arise on a complaint to a Professional Standards Department, a Police and Crime Commissioner, or indeed the IPCC itself. The advice would not be determinative of the complaint, but the fact that it was sought and received, as well as its content, would be a matter to be taken into account; (d) within the IPCC itself, there is a need for an enhanced 'filter system' whereby the nature of complaints are appropriately addressed at an early stage so that (a) they can be investigated at the right level, and (b) sufficient structures are put in place to maintain confidentiality of the complaint, and differentiate as soon as is appropriate between genuine whistleblowers and those who are merely ventilating a personal grievance; (e) the former Chief Constable referred to under sub-paragraph (c) above should also be the recipient of complaints about Chief Constables made to the IPCC. In the event that he or she may already have given informal advice in relation to the subject-matter of the complaint, as per sub-paragraph (c) above, a substitute HMI would be deputed to act; and (f) Chief Officers should also be the subject of regular independent scrutiny by HMIC, including through unannounced inspections.

The Inquiry recommended an enhanced system to protect police whistleblowers and provide ethical guidance. In May 2024, Lord Sharpe of Epsom, Parliamentary Under-Secretary of State at the Home Office, stated that the recommendations were accepted by the then Association of Chief Police Officers, superseded by the National Police Chiefs' Council, and that "all the recommendations have been addressed" (Lord Sharpe of Epsom, May 2024). In March 2018, the Department for Digital, Culture, Media and Sport reported that the Metropolitan Police Service, the College of Policing, and Her Majesty's Inspectorate of Constabulary and Fire & Rescue Services were implementing all law enforcement recommendations, noting that the Policing and Crime Act 2017 strengthened whistleblower protections (Department for Digital, Culture, Media and Sport response, Mar 2018).

Party Leaders, Ministers and Front Bench Opposition spokesmen should consider publishing: (a) the simple fact of long term relationships with media proprietors, newspaper editors or senior executives which might be thought to be relevant to their responsibilities and, (b) on a quarterly basis: i. details of all meetings with media proprietors, newspaper editors or senior executives, whether in person or through agents on either side, and the fact and general nature of any discussion of media policy issues at those meetings; and ii. a fair and reasonably complete picture, by way of general estimate only, of the frequency or density of other interaction (including correspondence, phone, text and email) but not necessarily including content.

The Inquiry asked politicians to publish relevant relationships and regular details of media contacts. In July 2013, Ed Vaizey, Parliamentary Under-Secretary of State for Culture, Media and Sport, stated in a written answer that the government publishes details of meetings held by ministers and special advisers with editors, proprietors, and senior media executives, but did not mention long-term relationships, interaction frequency, or opposition spokespersons (Ed Vaizey, Jul 2013). In November 2012, David Cameron, Prime Minister, had stated to the House of Commons that the government accepted the recommendation (David Cameron response, Nov 2012).