Complaints process

About IPSO's complaints process

This information sets out how your complaint will be dealt with once it is received by IPSO as well as our policies on confidentiality, behaviour and supporting individuals with disabilities.

Initial assessment

Once your complaint is received, IPSO staff will assess whether it falls within our remit and if it raises a possible breach of the Editors' Code.

If IPSO is not able to deal with your complaint, we will write to you to explain the reasons why we are unable to take forward your concerns and send a copy of your complaint, and our letter to the publication. 

If we receive a large number of complaints about the same issue which we decide requires investigation, we may choose a lead representative complainant, or choose to draft a summary of the complaints received to ensure that we are able to handle the issue proportionately and within a reasonable timescale. All complainants will be notified that the complaint will be handled in this way and will receive an update at the conclusion of the process.

Referral to the publication

If your complaint raises a possible breach of the Editors' Code, and you have not previously complained to the publication, we will generally pass your complaint to the editor, who will seek to resolve the matter directly with you. The time that your complaint is being handled by the publication’s internal complaints process is called the referral period.

In normal circumstances, we will take over the handling of your concerns once the publisher’s internal complaints procedures has concluded or if the matter has not been resolved after 28 days. Alternatively, the publication may request that we begin investigating the complaint without waiting for the end of the 28 days. In some circumstances we may begin to investigate the complaint immediately, without a referral period, if we consider it is essential for us to do so.

If at any time during the referral period you have any difficulties dealing with the publication directly, you should contact IPSO.

If your complaint is resolved by the publication during the referral period, please let us know as soon as possible. We will then close your file.  In cases where an agreement has been reached which resolves a complaint, and where the publication has taken the steps agreed as a remedy, IPSO will not generally re-open its file in the absence of some compelling reason to do so.

If we have not heard from you after 28 days, we will write to you to ask whether you wish to pursue your complaint and to request that you provide us with copies of your correspondence with the newspaper or magazine.

Investigation

If your complaint is not resolved through the publication’s internal procedures during the referral period, with your agreement, we will begin investigating your complaint. We will write to the editor of the newspaper or magazine to request its response to your complaint and may also ask you to provide further information.

You will be provided with a copy of the publication’s response to your complaint and given the opportunity to comment. We will seek to mediate a satisfactory outcome to your complaint if appropriate. This may be a faster resolution and provide a wider range of possible outcomes than the remedial action IPSO can potentially require. Examples include:

  • the publication of a correction, clarification or apology
  • the publication of a letter or article by a complainant
  • a private letter of apology
  • amendments to an online article or removal of material
  • assurances about future publication or conduct.

We try to conclude the majority of complaints within 90 days. To help us do so, we require that both publications and complainants comply with reasonable deadlines for replying to us, although we will always consider reasonable requests for additional time.

The Complaints Committee is able to take any unreasonable delay in correspondence into account in coming to a view on a complaint. Should a newspaper or magazine persistently fail to respond to reasonable requests for information in a timely way, the Committee may, after having given notice, adjudicate on the complaint without the information. In the case of complainants, if a complainant does not respond to correspondence, we will provide a reasonable deadline after which the complaint may be closed.

We will not generally reopen a complaint which has been closed because of a failure by the complainant to provide a timely response. Complainants who seek to do so will be asked to explain the reasons for their delay. IPSO will only reopen a complaint in circumstances where, in the view of its staff, to refuse the request would be unreasonable.

Adjudication by the Complaints Committee

If your complaint remains unresolved, the Complaints Committee will decide whether there has been a breach of the Editors’ Code. The Complaints Committee will take into account only information which has been seen by both sides to the complaint, and will publish its decision setting out whether the Editors’ Code has been breached, and why, on our website.

Outcomes

If the Complaints Committee determines that the Editors' Code has been breached, it can require the publication of its upheld adjudication and/or a correction. The nature, extent and placement of corrections and adjudications will be determined by the Committee.

In cases where the Committee finds that arrangements for upholding standards and compliance were at fault, IPSO may also inform the publisher in writing that further remedial action is required to ensure that the publication meets the requirements of the Editors’ Code.

Anonymity

All of IPSO's decisions are published on the Rulings section of our website, unless there are special circumstances such as a court order. If you have concerns about publication of a decision, you will be given an opportunity to raise them before the Complaints Committee is asked to consider the complaint.

The Complaints Committee considers requests that material should not be included in its published decisions on a case-by-case basis, but starts from the standpoint that decisions should generally be published in full, except in cases involving intrusion into privacy or where IPSO is satisfied that the complainant has a legal right to be anonymous.

In considering requests that decisions be anonymised, the Committee takes into account:

  • whether the subject includes information which is private or sensitive or could cause distress, embarrassment or harm to the complainant
  • whether the decision could identify the complainant as a confidential source
  • whether inclusion of the complainant’s name in the decision could cause significant harm to a third party
  • whether inclusion of the complainant’s name in the decision could represent a specific threat to their security.

The Committee will only agree to anonymise a decision having first considered whether there are other means by which a complainant’s legitimate concerns could be addressed. It may refuse to grant anonymity but agree to omit specific information from a published decision.

To avoid prejudging a complaint, the Committee will generally grant anonymity where it appears that there is a significant overlap between the reasons for the anonymity request and the grounds for the complaint. If the Committee declines your request, you will have the opportunity to withdraw your complaint. The Committee will not generally consider requests for anonymity made after a decision has been issued.

Review

If your complaint has been the subject of a decision following investigation and you believe that the procedure by which the Committee considered the complaint was substantially flawed, you may request a review by the Complaints Reviewer. Any request for a review must be made in writing within 14 days of the decision being issued. IPSO's staff will decide whether to refer the complaint to the Complaints Reviewer.

The Reviewer will look at the process by which the decision was reached and inform the Complaints Committee within 14 days whether it considers that the process was substantially flawed.  If the Reviewer agrees, the decision will be reviewed by the Complaints Committee, taking into account the Complaints Reviewer’s findings. The Committee will then issue its findings. If the Reviewer does not consider that the process was substantially flawed, the decision will be issued.

Confidentiality

Complainants and others should have absolute confidence that their privacy will be respected. In order for IPSO to be able to investigate complaints effectively, it is essential that neither party publishes information which has been provided as part of the investigation, including correspondence, without the consent of the other. Material provided by both parties during an investigation must only be used for the purpose of the complaint. This does not prevent either party from disclosing information about the complaint to third parties in order to seek assistance, so long as they take reasonable steps to ensure that the third parties are aware of and will respect confidentiality.

Decisions by the Committee remain confidential until published by IPSO.

A failure to abide by IPSO’s policy on confidentiality may affect our ability to continue to deal with a complaint or, if relevant, may be considered when the Committee reaches a decision on the complaint.

Significant, repeated or deliberate disclosure of confidential information by a newspaper or magazine may be regarded by IPSO as raising concerns about the publication’s standards.

Significant, repeated or deliberate disclosure of confidential information by a complainant may be dealt with by IPSO in accordance with its policy on unacceptable behaviour by complainants.

Simultaneous correspondence

IPSO is committed to resolving complaints, where possible and appropriate, on terms which are agreeable to both sides.  We expect both parties to a complaint to engage with the process in good faith, and to cooperate with our procedures.

We acknowledge that parties may wish to engage in confidential correspondence about press complaints, and we do not seek to prevent that; IPSO processes expressly recognise the right for a complainant to complain directly to a publication in the first instance. However, once we have begun an investigation into a complaint, the existence of simultaneous correspondence between the parties directly inhibits our ability to investigate and mediate in an effective and transparent way. For this reason, during an IPSO investigation, all correspondence about the complaint should be conducted through IPSO and the parties should not engage in separate simultaneous correspondence, whether on an open or without prejudice basis.

Complainants and publications will be notified at the start of our investigation that all correspondence should be conducted through IPSO. If the parties wish to engage in direct correspondence, without our involvement, they should notify us, so that the IPSO complaint file can be closed.

Should we become aware that the parties are exchanging correspondence direct, we will ask both parties to cease corresponding outside of the IPSO process. If the complainant declines to do so, the IPSO complaint file will be closed and marked as ‘not pursued’. A refusal by a publication to cease corresponding outside of the IPSO process would raise standards concerns, as it would constitute a failure to handle complaints in accordance with our procedures.

Should complainants or publications repeatedly fail to comply with this policy, we will consider taking further action, which may include declining to consider further complaints.

Multiple complaints

In cases where IPSO receives a large volume of complaints about a general point of fact, they will be combined into a single “lead or “summary” complaint, either prior to or following referral. If a lead complainant is selected, other complainants will receive an explanation of this, and will be notified of the outcome at the conclusion of the process.

If a lead complaint is resolved by IPSO, a resolution statement will be published, and sent to the other complainants. If another complainant is dissatisfied with the resolution, the Complaints Committee will be asked to consider whether it would be proportionate to re-open the complaint, taking into account the nature of the concerns raised and remedial action offered.

Individuals with disabilites

IPSO will make reasonable adjustments to our ordinary procedures in order to accommodate your needs. Please explain the nature of your disability and any adjustment you require.

IPSO must ensure that the complaints process is transparent, effective and fair to both parties. Generally speaking, this requires a written record of the nature of the complaint, the response by the publication and the process that has been followed. All complaints are presented to the Committee for consideration in writing.

If we are unable to meet your request fully, we will explain why. If you have concerns that the accommodation offered is not sufficient we will consider further your request and the outcome. Contact IPSO for further information.

Unacceptable behaviour by complainants

We understand that in some cases, complainants will contact IPSO in distressing circumstances and may need significant support and assistance. Our staff should be accessible and courteous to everyone.

However, in a small minority of cases, complainants seek to interact with staff in an unacceptable way. IPSO’s Regulations make clear that it may reject, without further consideration, complaints which are vexatious or disproportionate. This applies both to the nature of the complaint and to how it is pursued.

We do not expect our staff to tolerate unacceptable behaviour including:

  • vexatious or disproportionate pursuit of a complaint
  • behaviour that because of its frequency or nature hinders our ability to handle complaints effectively
  • using abusive, offensive, aggressive, racist or foul language in conversation or correspondence with staff
  • harassing, verbally abusing or seeking to intimidate staff
  • engaging in unreasonably protracted or repetitive communications with staff
  • attending IPSO’s offices and seeking to speak with a member of staff without an appointment
  • repeatedly refusing requests by staff to follow IPSO’s procedures
  • making persistent and/or unreasonable demands of staff and/or the complaints process.

We reserve the right to take appropriate action in cases where complainants are behaving unacceptably including restricting the manner in which the complainant may communicate with our staff or declining to further consider a complaint.

Complaints about IPSO

Complaints about IPSO’s complaints process that fall outside the remit of the Complaints Reviewer should be made in writing to the Chief Executive, Matt Tee