PPA Policy Manifesto

Five key asks of the new Labour government:

• Transparency and IP in the context of AI.

• Fostering digital competition and optimising business conditions for specialist publishers.

• Media plurality and the value of specialist publishing to the citizen.

• Media regulation and protecting Saturday deliveries.

This has been developed in thorough consultation with members and aims to support the manifesto development of the key political parties in the UK as they prepare for the 2024 election. We are sending it to our key political contacts and will be reinforcing these messages through our lobbying activity. You can read the manifesto in full below.

1. Transparency and Intellectual Property (IP)

The PPA believes that the next Government must ensure that the transparency provisions proposed in the AI White Paper are enforced so that copyright laws can be realised in the context of AI.

Recent developments of artificial intelligence (AI) systems, such as ChatGPT, have introduced exciting new ways of consuming information. Now, you can ask a chatbot almost anything: to write a review of the latest film, to provide a recipe for your favourite meal, or to recommend somewhere to buy a new laptop.

However, the answers we get from these chatbots come from data that has been scraped from specialist publishers without their permission or any form of payment. This undermines the financial sustainability of the specialist publishing sector as publishers are being denied the ability to assert their copyrights and monetise their content.

Therefore, the next Government must set out a strategy for regulatory enforcement of the transparency provisions proposed in the AI White Paper. This is so publishers can understand how their content has been deployed, assert their copyrights, and identify where infringements have taken place.

The Intellectual Property Office (IPO), which is the official UK Government body for IP, has been developing a code of practice on AI and copyright in consultation with the PPA which looks at the issue of transparency.

However, for this code of practice to be effective, the PPA believes that the next Government must:

  • Ensure that this code of practice is on statutory footing, either by giving the IPO additional enforcement powers or assigning additional responsibilities to an alternative regulator, such as the Information and Commissioner’s Office (ICO).

  • Assign a duty to the Secretary of State to review the regulatory effectiveness of the transparency requirements over the next two years. 
2. Fostering digital competition and optimising business conditions for specialist publishers

The PPA believes that the next Government should prioritise the empowerment of the Digital Markets Unit (DMU) and ensure that it is equipped to tackle market failures stemming from uncompetitive practices of platforms and AI developers.

Such practices include:

  • Rapid changes to algorithms in Google search and Facebook News Feed without notice or explanation.

  • Centralisation of access to, and monetisation, of user-data.

  • Opaque data scraping practices of AI developers.

The unregulated market conditions have come at the expense of specialist publishers as it has allowed a small number of large companies (such as Meta, Google, and Amazon) to use content to entrench market power. These companies have been able to control user algorithmic serving on their websites, and hence steer users towards or away from particular content. They have also dominated the UK’s digital advertising market. From this position as aggregators, they continually collect vast resources of audience and behavioural data which is used in turn to support pricing power and product development.

More recently, with developments of AI, as chatbots such as ChatGPT continue to grow and become an entry point for digital information services, specialist publishers will have their content used and read, but not paid for.

The government should ensure that the impact of these market failures on publishers is included in its strategic steer for the Competition and Markets Authority (CMA).

Further, the DMU should seek to understand the many impacts on competition that the platforms’ data assets help to entrench and consider how this can be addressed on behalf of publishers and consumers.

3. Media Plurality and the value of specialist publishing to the citizen

The PPA believes that the next Government must introduce a statutory duty on the CMA to further the interests of citizens as well as consumers.

This would ensure that anti-competitive practices are addressed in the broader interests of society, and account for the need to protect media plurality and access to specialist publishers’ content.

Ofcom characterises media plurality as the accessibility and consumption of a diverse range of viewpoints across and within media enterprises.[1] Media plurality is important as it promotes accessibility to trusted, reliable sources of information and expertise. This includes specialist publishers who give niche insights on issues affecting industries and communities with particular interests. Some identity groups who have been alienated from mainstream media also rely on specialist publications to access key information and updates.

However, the legislation going through parliament to empower the DMU restricts its role to protecting consumer interests. The PPA urges the next Government to assign the DMU a statutory duty to protect citizen interests so that the value of specialist publishing to society can be recognised and protected.

[1] Ofcom 2011 “Measuring Media Plurality”.

4. Media Regulation

The PPA believes that the next Government must commit to independent regulation of publishers.

The Independent Press Standards Organisation (IPSO) has been effectively regulating the sector for nearly 10 years. Therefore, the introduction of a state-backed regulator is entirely unnecessary and would cause disruption to specialist publishing businesses without good reason.

5. Protecting Saturday deliveries

The PPA believes the next Government must protect Saturday letter deliveries.

The Royal Mail has a Universal Service Obligation (USO) to deliver letters six days a week (Monday to Saturday). In recent years, we have seen Royal Mail attempting to reduce their service and remove Saturday deliveries. This would have an adverse impact on the specialist publishing sector, which makes many important deliveries, often subscriptions, on Saturdays.

Conclusion

The upcoming general election is an opportunity to elevate the standards and effectiveness of digital regulation in the age of AI. The specialist publishing sector believes that the next Government should prioritise digital regulation with respect to both copyright and competition. We also believe that the scope of the DMU should be broadened, to allow it to promote the interests of citizens and support the Government’s protection of media plurality.

The PPA also believes that the new Government should work to ensure that publishers are able to continue to be regulated independently, without unnecessary state interference. Finally, we believe that the next Government must ensure that Saturday deliveries are not eroded, and that Royal Mail continue to deliver on their six-day service obligation.

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