Our complaints process

We welcome enquiries in any form but complaints must ordinarily be made in writing. The simplest way is through our complaints form, although they can be made by email or post.

As part of making a complaint, you may provide us with personal data about you. We will use this information to administer our complaints procedure. We may share this information with the publication complained about, even if the complaint is not taken forward. This ensures that they are aware that a complaint has been made about them and the outcome.

You should let us know if you have concerns about this, and we will be happy to discuss it with you. It may be the case that we do not have to include certain information that you have given to us. We do not generally take forward anonymous complaints, but we may publish any ruling anonymously.

More information about what we do with your personal information can be found in our data privacy notice.

We are 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. Our 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 – this means direct correspondence between the parties while an investigation is ongoing – 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 us and the parties should not engage in separate 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 us. If the parties wish to engage in direct correspondence, without our involvement, they should notify us, so that their complaint file can be closed.

Should we become aware that the parties are exchanging correspondence directly, we will ask both parties to cease corresponding outside of the our complaints process. If the complainant declines to do so, their 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.

Anyone can complain to us about a significant inaccuracy which has been published on a general point of fact (under Clause 1 of the Editors’ Code).

We can take forward complaints under Clauses 2–16 of the Code from anyone directly affected by editorial material or a journalist’s behaviour (or, with their permission, a representative like a family member, solicitor, or trusted friend). Complaints made under these clauses by people with no connection to a possible breach of the Editors’ Code are known as ‘third party’ complaints and our regulations do not allow us to take these forward.

We understand that many members of the public who make complaints about stories that do not directly concern them do so because they want to protect the subject of the story in question and feel that we all benefit from having a press that is accountable and upholds the standards set out in the Editors’ Code. While these complaints are not taken forward through the complaints process, they are fed into the work of our Standards team, who perform wider monitoring of the media landscape. We also make direct contacts to relevant agencies when we have reason to believe that there are concerns about press activity, for example at the scene of a major incident.

Our regulations have a special mechanism for recognising the voices of others who may be affected by coverage that potentially breaches the Code. This is known as a representative group complaint.

If a person complains about the accuracy of an article, but they are not the subject of the coverage (what we call a third parry complaint), we take their position into account and decide whether to investigate, based on the appropriateness and feasibility of investigating and ruling on the issue.

For complaints about other (non-accuracy) issues, such as harassment, privacy, or discrimination, we cannot consider complaints from third parties. This is for several reasons, but an important one is that people unconnected with the story do not know how the directly affected person feels about the coverage or about making a complaint. They should be free to make their own decision about how they would like to respond.

However, where there is a significant alleged breach of the Editors’ Code and a public interest, IPSO’s regulations enable us to investigate complaints from representative groups affected by the breach. This is a way of recognising the voices of people who may be affected by coverage that potentially breaches the Code.

If you complain to us on the basis that you are a representative group, our Complaints Committee looks at a number of criteria when deciding whether to take forward the investigation. To help them reach a decision, we will ask you to explain:

Which group you believe has been affected by the alleged breach of the Editors’ Code

• How you are representative of that group
• How you believe the alleged breach is significant
• How you believe the public interest would be served by considering the complaint.

We do not need the agreement of the subject of the article to investigate a representative group complaint, although we will take their position into account and may communicate with them about the progress of the investigation or the outcome, depending on the circumstances of the case.

If the Complaints Committee decides to take a representative group complaint forward, it will proceed as a normal IPSO investigated complaint from that point.

We can only consider complaints about user-generated material, including reader comments, after they the publication has been given the chance to review or moderate the comment in question, and where a specific breach of the Editors’ Code has been alleged.

We do not generally consider complaints about publications not publishing reader comments, or about allowing reader comments on an article, unless the Editors’ Code has been otherwise breached.

We are able to consider complaints within four months from the date of the conduct complained about, or the publication of the article.

We may be able to consider complaints about material that remains published on the publication’s website, if a complaint is received within 12 months of publication. This is only if it is still possible for it to investigate and adjudicate fairly.

IPSO does not generally reopen a complaint which has been closed because of a failure by the complainant to provide a timely response. Complainants who want to reopen complaints that have previously been closed due to a lack of a response are asked to explain the reasons for the delay in their response. IPSO only agrees to reopen a complaint where, taking account of the reasons given and the full circumstances of the complaint, to refuse the request would be unreasonable. It is IPSO’s Complaints Committee who consider these requests.

We do not generally take forward anonymous complaints.

If we help you to resolve your complaint or our Complaints Committee rules on your complaint, we will publish a resolution statement or the Committee’s decision on our website in full which will include your name.

You can make a request to our Complaints Committee that the decision is published anonymously and/or has identifying details removed. Requests are considered on a case-by-case basis, but the Committee starts from the position that decisions should generally be published in full, except where a complainant had a legal right to anonymity, or where a decision includes sensitive information about a child who hasn’t previously been identified, and naming the complainant would identify the child. In adjudicating on complaints about the publication of information that the complainant believes to be private, the Committee will generally avoid republishing the relevant information, except to the extent that it is necessary in order to make clear the grounds for the complaint, the publication’s response, and the reasons for the Committee’s decision. The Committee will take into account the effect of publication on the complainant or third parties.

They will consider the following when deciding whether a decision should be published anonymously or have certain details removed:

• Whether the subject matter of the complaint includes information about the complainant which is private or personally sensitive, could cause the complainant distress or gratuitous embarrassment, or could otherwise cause harm to the complainant (e.g. harming their relationship with an employer).
• Whether the complaint could identify the complainant as a confidential source of information.
• Whether inclusion of the complainant’s name in the decision could cause significant harm to a third party.
• Whether the inclusion of the complainant’s name in the decision could represent a specific threat to their security.

In cases where we receive a large volume of complaints about a general point of fact, they will be combined into a single “lead” or “summary” complaint. 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 all complaints are combined into a summary complaint, we will again explain this to all complainants and they will be updated at the end of the IPSO process.

If a lead complaint is resolved by our complaints process, we shall send the offer of resolution to the other complainants. If all complainants accept the proposed remedy as a satisfactory resolution to their complaints, the complaint shall be closed.

We will, wherever possible, make reasonable adjustments to our ordinary procedures in order to accommodate the needs of anyone who can’t follow our usual complaints process, for example, people with disabilities. Please contact us to explain any adjustment you require and the reasons for this.

We must ensure that our 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 any accommodation we have offered is not sufficient we will further consider your request and the outcome.

Where a complainant and publication reach an agreement to close a complaint as resolved, they should let us know within 14 days. We will treat this complaint as resolved and will close the file. If there is a dispute about whether an agreement has been reached, we may ask to see the correspondence between the parties in order to decide whether it would be appropriate to reopen any complaint. Where we are satisfied that an agreement has been reached which resolves the complaint, and where the publication has taken the steps agreed, we will not generally re-open its file unless there is a compelling reason to do so.

We recognise the right of children to seek redress where they are concerned about published materials. However, we must balance this with the need to respect their welfare.

We will accept all complaints submitted by anyone over 18, and will generally accept complaints from anyone over 16 unless there are exceptional circumstances which require additional caution, where we will also seek the consent of a parent or adult with parental responsibility.

If a complainant is under 16, we will contact their parent or guardian to make sure they are aware the child has made a complaint and obtain their written consent to take that complaint forward. If we are not able to obtain consent we will be unable to deal with the complaint.

If a child’s complaint is taken forward, we will forgo the referral period (where the newspaper has an opportunity to resolve the complaint directly with the complainant) and and move straight to investigation.

If a child wants to accept an offer of resolution we will seek the consent of the adult with parental responsibility. Likewise, before putting the complaint before the Complaints Committee for a published ruling we will seek the consent of the responsible adult.

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

In a small number of cases, complainants seek to interact with our staff in an unacceptable way. In cases like these, we 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 our offices and seeking to speak with a member of staff without an appointment
• repeatedly refusing requests by staff to follow our 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.

This policy also applies to contacts with any staff who may be handling your complaint at our member publications.

Any attempt by a publication to abuse its internal complaints process to discourage or deter a complaint, or to intimidate or distress a complainant, is considered an extremely serious breach of standards and will be escalated.

We do not ordinarily consider complaints if the parties are engaged in active legal correspondence regarding the material under complaint because our ability to consider the complaint or publish a decision may be inhibited.

IPSO’s regulations define what a global digital publisher is and set out what foreign, online content may be outside of IPSO’s jurisdiction at page 2. They state:

2. With respect to material published online by a Regulated Entity designated by the Regulator as a Global Digital Publisher in accordance with Regulations 85-90, the Regulator shall have jurisdiction to regulate such content when one of the following criteria applies:

2.1 The content relates to events within the UK.

2.2 The content concerns a UK national or resident of the UK at the time of publication who is directly and personally affected by the alleged breach of the Code, save that the Regulator shall have jurisdiction to consider a complaint brought under Clause 1 of the Code (Accuracy) which meets the terms of Regulation 8 (c), provided that it concerns a UK national, a resident of the UK, or a UK institution.

2.3 The content is based on material that has been published in a UK print title within the Global Digital Publisher’s group.

The following publishers have been recognised as global digital publishers under IPSO’s regulations (see 89 to 93, page 15 for criteria):

Reach
News UK
Associated

What this means is that certain content published online only by the above publishers does not fall within IPSO’s remit, as it does not relate to events within the UK or to a UK national or resident.

If you are unsure about whether something you have seen online fits this criteria, please do get in touch.

For more information, please contact us.

So we can effectively investigate complaints, neither the publication or the complainant should publish information provided as part of the complaints process. This material must only be used for the purpose of the complaint. This does not prevent either party from disclosing information to a third party in order to seek assistance with the complaints process, but they must take reasonable steps to ensure confidentiality.

A failure to abide by this may affect our ability to continue to deal with the complaint or may be considered as part of making a decision about whether the Editors’ Code has been breached.

Significant, repeated or deliberate disclosure of information by a publication would be considered a serious standards issue.

Significant, repeated or deliberate disclosure of information by a complaint may be considered unacceptable behaviour.

Complaints about our process that fall outside the remit of the Independent Complaints Reviewer should be made in writing to the Chief Executive via inquiries@ipso.co.uk

Find out more in our Complaints FAQs