Does Pickles think that Wirral Council’s £22,500 newspaper plan “pours taxpayers’ money down the drain”?

Does Pickles think that Wirral Council’s £22,500 newspaper plan “pours taxpayers’ money down the drain”?

Does Pickles think that Wirral Council’s £22,500 newspaper plan “pours taxpayers’ money down the drain”?

                         

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The point in the video above of the Birkenhead Constituency Committee meeting where the “community newspaper” proposals starts is at 21:28

Birkenhead Constituency Committee (10th April 2014) Birkenhead Town Hall
Left to Right Surjit Tour (Head of Legal and Member Services), Councillor George Davies, Rt Hon Frank Field MP (Chair), Dawn Tolcher (Birkenhead Constituency Manager)

Prior to the Birkenhead Constituency Committee meeting held on the 10th April that decided to go ahead with the “community newspaper” idea, Graham Burgess (Wirral Council’s Chief Executive) would have received this letter from the Department of Communities and Local Government about council’s compliance with the Code of Recommended Practice on Local Authority Publicity.

I won’t include the letter here as you can click on the link and read it in its entirety yourself, but I will quote some sections “The background to the new power is that whilst the majority of local authorities comply fully with the Publicity Code’s provisions, it is a matter of concern to the Government that there are still cases where this is not so, for example, local authorities issuing publicity that is political in nature or continuing to publish newspapers more frequently than stated in the Code’s provisions. The Secretary of State being able to direct compliance with the Publicity Code is a means whereby these concerns can be addressed” and “The Secretary of State intends to adopt the following approach to this consideration. Where on the basis of any material or information currently available to him, the Secretary of State considers that there is some evidence of non-compliance since the Publicity Code was issued in March 2011, and there is no current unambiguous evidence available to him that the non-compliance has ceased and that there is no risk of future non compliance, he will be minded to give a direction to the authority concerned.”

So what does the code state on frequency?

Section 28 quite clearly states “Where local authorities do commission or publish newsletters, news-sheets or similar communications, they should not issue them more frequently than quarterly, apart from parish councils which should not issue them more frequently than monthly.”

So what frequency was approved by the Birkenhead Constituency Committee? I quote from the report on it, “It was proposed to produce a monthly publication to include information residents want to read about.” and later on it describes the frequency of the issues as “The pilot would be to produce an 8 page publication, bi-monthly for 6 months (3 editions) working in partnership with Lairdside Communities Together.”

Moving to the bit in the letter that states “it is a matter of concern to the Government that there are still cases where this is not so, for example, local authorities issuing publicity that is political in nature” the report to the Birkenhead Constituency Committee states “The content of the publication would be devised from the committee and community requests.” Everyone on the Birkenhead Constituency Committee is a politician (whether councillor or MP), does the public expect their requests for what goes in it not to be political. As there won’t be any advertising in the first three editions personally I don’t think there will be enough “community requests” for three eight page editions so the majority of the content is likely to be suggested by politicians.

Here was what was said at the Birkenhead Constituency Committee meeting on this item which starts at 21:28 in the video above.

=======================================================================================================DAWN TOLCHER (BIRKENHEAD CONSTITUENCY MANAGER)
The second item on this Councillor Doughty talked to last time was around a local publication, so we’ve done some further thinking around this and just to clarify what this will be, it will be a community focussed publication supporting people with what’s on in the community. The data shows that the feedback that a lot of Members get is not all our residents get the local newspaper currently.

It will be a focus on work with other public sector organisations and we’ve got a group together called of the Birkenhead public services. What I’ve asked from them is what they currently do around their communication, what spend, what tools they use and I’m collating that together to look at across us all what we use and what we’re spending, what are we doing and is there any way we can pull that together.

What we’re asking from the Committee is a pilot of three editions to see if it works and to monitor that pilot there will be two subgroups and one will look at it will be an editorial board that will ensure the content is non political and it’s what people want to read on the feedback we’re getting.

It’ll aim to recruit an apprentice for nine to twelve months and involve the community around the community news and how that’s developed. So we’re talking as people have been appearing through this there’s been a really positive feedback from some, from a lot of people saying we’ve had for example a few of have been today at a conference around food planning and how people are struggling accessing food and what, there’s massive support out there with people saying I don’t know where it is around initiatives such as somebody wrote to Councillor Kenny saying that we’ve got an initiative around supporting to access free bikes and that’s the sort of information to go in there. Any questions?

RT HON FRANK FIELD MP (CHAIR)
Questions on that? Yes please, yep?

MEMBER OF PUBLIC
Did you find out about whether the Council actually paid additional money to have the newspapers circulated everywhere? Did that actually happen?

DAWN TOLCHER (BIRKENHEAD CONSTITUENCY MANAGER)
My understanding was that it used to happen, it doesn’t happen now.

MEMBER OF PUBLIC
So it’s too late to have any redress for it?

RT HON FRANK FIELD MP (CHAIR)
Phillip I think we should actually follow that up, it’s a serious point. Can we actually have that in the minutes please and follow it up? What happened to that?

COUNCILLOR CHRIS MEADEN
As I understand it, that’s what we used to do.

RT HON FRANK FIELD MP (CHAIR)
Yeah, absolutely, yeah.

DAWN TOLCHER (BIRKENHEAD CONSTITUENCY MANAGER)
What we have got since the last meeting is a breakdown of where it is going and where it isn’t going so we can help with that.

RT HON FRANK FIELD MP (CHAIR)
So what we’re going to be doing, again it comes back to this whole point what does the contract say and is it actually being fulfilled, if not what do we do about it? (At this point he looks at officers to his left and says sotto voce “answer this evening”)? Really, thanks.

=======================================================================================================

What’s interesting is Dawn Tolcher states that the community newspaper will have a “focus on work with other public sector organisations and we’ve got a group together called of the Birkenhead public services. What I’ve asked from them is what they currently do around their communication, what spend, what tools they use and I’m collating that together to look at across us all what we use and what we’re spending, what are we doing and is there any way we can pull that together.”

There’s something called the Wirral Public Service Board. Last year I made a Freedom of Information request to Wirral Council for the agendas and minutes of their meetings over the previous year. That request was refused by Surjit Tour under s.36 (2) (b) (ii) of the Act stating that releasing the agendas and minutes would (or would be likely to) inhibit “the free and frank exchange of views for the purpose of deliberation.” and have a “chilling effect” on their discussions. He also refused it on the basis that the minutes would contain the names of people (data protection grounds).

So just to recap, Wirral Council won’t release the agendas and minutes of meetings held with other public sector organisations at which the decisions and discussion about joint working are made. However they plan to write articles about the decisions made at these meetings and the joint work that Wirral Council is doing in a publication they plan to send out to 39,823 properties in Birkenhead? Oh and after the third edition Wirral Council will charge these other public sector organisations to include details about these projects in their “community newspaper”?

I don’t believe there is as much support for this community newspaper idea as was claimed at the Birkenhead Constituency Committee meeting. I previously wrote about this proposal and included a poll. The poll’s question was “Do you think Wirral Council should spend £22,500 to start a community newspaper in Birkenhead?” with the three following answers to choose from yes, no and don’t know. At the time of writing nineteen people had answered the question. The results were clear, eighteen said no and one answered don’t know.

So did Wirral Council’s Chief Legal Eagle Surjit Tour point out Eric Pickle’s new legal power (which has been in force since the 30th March 2014) to direct Wirral Council to comply with the code (which as outlined above the proposal as it stands doesn’t)? No Mr. Tour didn’t (but then he wasn’t asked for any legal advice on this item). The taxpayer pays him a salary of £73,352 a year. His role (according to Wirral Council’s constitution at 2.3 of Wirral Council’s financial regulations) is defined as follows “The Monitoring Officer is responsible for reporting any actual or potential breaches of the law or maladministration to the Council and/or to the Executive”.

No councillor or MP asked Surjit Tour during the meeting whether aspects of the proposal for a community newspaper were lawful and for his advice. Surjit Tour didn’t say anything during this item and the letter from the Department of Communities and Local Government went to Graham Burgess (so it seems likely that Surjit Tour hasn’t seen it).

The letter from DCLG finishes with “If you have any questions about the new powers, please contact ConductCode@communities.gsi.gov.uk. You can also contact the Rt Hon Eric Pickles MP directly at eric.pickles@communities.gsi.gov.uk.

The Rt Hon Eric Pickles MP said about the very issue of Council newspapers “The spread of the town hall ‘Pravda’ is manifestly unfair because they offer cut price local news, but mixed in with council propaganda that pours taxpayers money down the drain.

These free-sheets are often confused for the real thing by residents. I want our news to be told and sold under the masthead of an independent and free press, not through a knock-off Rolex imitation.”

The press release goes on to state “Where a council ignores the statutory code, the government or a concerned member of the public could seek a court order to enforce it. Disregard for that would result in contempt of court.”

So is Wirral Council going to change its plans or run the risk of a showdown with the Rt Hon Eric Pickles MP over their newspaper plans? The Liverpool Echo also ran a story about this on the 26th March using the headline FURY OVER TOWN HALL PAPER PLAN; Town could see launch of newsletter.

I’d be interested to read your thoughts on this issue which you can leave as a comment (even anonymously if you wish) or contact the Department for Communities and Local Government or the Rt Hon Eric Pickles MP directly yourself to let them know your views on what Wirral Council is proposing to do.

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Government promises regulations to compel councils to allow filming at their public meetings

Government promises regulations to compel councils to allow filming at their public meetings

Government promises regulations to compel councils to allow filming at their public meetings

                     

Cllr David Elderton shows photos of pavement parking problems to the politicians on Wirral Council's Regeneration and Environment Policy and Performance Committee
Cllr David Elderton shows photos of pavement parking problems to the politicians on Wirral Council’s Regeneration and Environment Policy and Performance Committee: An example of the kind of public meeting that the new regulations will cover

Following up on my earlier blog post calling for consultation with those actually doing filming of local government meetings on new regulations, I’ve received a response from one of the Rt Hon Eric Pickles MP’s spads (special policy advisers).

I made it clear that I’d publish any reply I received. Apart from the news though that the Local Audit and Accountability Bill has since received Royal Assent (which means parts of it are now law and it’s referred to as the Local Audit and Accountability Act 2014) the letter doesn’t say much more than has already been stated in public on this matter. I’ve changed the @ in my email address to [at] to try to fool bots that collect email addresses to spam them.

(DCLG logo)
Department for
Communities and

Local Government

Mr. John Brace

Via email
John.brace [at] gmail.com

Our ref: ER74/00629/74
Your ref:

30 January 2014

Dear Mr. Brace,

Section 40 of the Local Audit and Accountability Bill

Thank you for your email of 23 December to the Secretary of State about the provisions in section 40 of the Local Audit and Accountability Bill, which relate to access to local government meetings and information.

I am pleased to inform you that the Bill has now become law as it received Royal Assent today. This means that the Secretary of State has power to make regulations any time after March that may allow local people including citizen journalists to attend public meetings of the local government bodies listed under section 40(6) of the Act and report the proceedings by using various communication methods such as filming, tweeting and blogging. This is a significant change in favour of openness and transparency, as, once secondary legislation is made, councils and other local bodies will be compelled to allow the public to film or tweet at their public meeting.

On your point about consultation, although the Local Government Association and the National Association of Local Councils were mentioned during the debate, no decision has been made on all those who will be consulted. However your point about consulting the people the proposed will affect will be considered when the decision is made.

Also, your points about the circumstances in which persons may not carry out activities such as filming at councils’ meetings and the extension of provisions on offences have been noted. They will be considered when developing the regulations.

Yours sincerely

Tayo Peters
Democracy and Local Governance

Department for Communities and Local Government
3/J1 Eland House
Bressenden Place
London
SW1E 5DU

Tel 030 3444 0000

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Blogger calls for Rt Hon Eric Pickles MP to consult public and press on local Council filming law

Blogger calls for Rt Hon Eric Pickles MP to consult public and press on local Council filming law

Blogger calls for Rt Hon Eric Pickles MP to consult public and press on local Council filming law

                          

Jenmaleo,
134 Boundary Road,
Bidston,
Wirral
CH43 7PH

Rt Hon Eric Pickles MP
Department for Communities and Local Government,
Eland House,
Bressenden Place,
London,
SW1E 5DU
eric.pickles@communities.gsi.gov.uk

23rd December 2013

Dear Rt Hon Eric Pickles MP,

As it is standard protocol to write to one’s own MP if one wants a reply from a Minister, I am also emailing a copy of this letter to my MP (the Rt Hon Frank Field MP). I am also publishing it on my blog and would be happy to publish any replies I receive to this letter.

In June 2013 your department published a press release titled Lights, camera, democracy in action that referred to problems I had earlier this year filming a meeting of Wirral Council’s Pensions Committee where the reason of “health and safety” was given. Your press release also referred to the Health and Safety Executive’s Myth Busters Challenge Panel’s view that the Council was “clearly hiding behind ‘health and safety’ as a convenient excuse rather than giving the real reasons for its concerns about full openness and transparency.”

In October you issued a further press release stating that a new law will give the press and public new rights to film and report council meetings (making specific reference to the Local Audit and Accountability Bill).

Since then a new clause was added to the Local Audit and Accountability Bill called “Access to local government meetings and documents“.

Once the Local Audit and Accountability Bill becomes law, this section will come into force two months later. However this section does not immediately (as was implied in your October press release) “confer new rights to film and report council meetings” as the only power it grants is to the Secretary of State for Communities and Local Government (currently yourself) to come up with further secondary legislation on this issue.

I quote from what was said on the 21st November 2013 when this section was discussed at the Public Bill Committee stage by Brandon Lewis MP (the Parliamentary Under Secretary of State at the Department for Communities and Local Government),

“It is fair to say that people should not be able to disrupt meetings. At the same time, however, we must get the balance right, as the regulations will, and we shall talk to the LGA about that. We must make sure that an authority does not use disruption as an excuse to stop people filming a meeting in a non-disruptive sense”, later he also said,

“That is why we will liaise with partners to make sure that the regulations are correct. We want to make sure that meetings are not disrupted, but, equally, that disruption cannot be used as an excuse to block fair and proper transparency. It is the inconsistent and unjustifiable excuses that councils occasionally use to refuse public access that we want the clause to address. Our intention is to make regulations that require local government bodies, including their committees, sub-committees and joint committees, to allow people to film, photograph, tweet and blog at their public meetings.”

In reference to the future regulations he said,”They may also specify that government bodies may reasonably ask for the filming or photographing to be done in such a way that they are not disruptive to the good order and conduct of the meeting.” and also “the Government intend to work with the LGA and the National Association of Local Councils to cover the detail of the regulations.”

I am concerned that as the government has only stated they will consult with the Local Government Association and the National Association of Local Councils on the detail of the regulations, that these two bodies will have the opportunity to comment on and suggest amendments to the regulations, when there is no commitment from the government that the people these regulations will affect (such as myself) who are currently filming local government meetings are to be consulted when the regulations are in draft form.

There are those who currently film local government meetings, bloggers who use clips of local government meetings in what they write, other members of the press, the public and other bodies (such as the National Union of Journalists) that may wish to comment on the detail of any draft regulations. Unlike primary legislation when members of the public can make submissions about proposed laws at the Public Bill Committee stage, I am not aware of any similar stage to secondary legislation (also referred to as regulations).

Three aspects worry me as to what could be in the regulations (especially as you have only committed to consult bodies representing local government views). I would appreciate the courtesy of a detailed response to these concerns. These concerning sections are in s.40 of the Local Audit and Accountability Bill.

“(2)Regulations under subsection (1) may in particular make provision—

(c)about the steps to be taken by persons before carrying on such activities;”

I presume this is about informing the body being filming before filming. However if filming is a “right”, why should someone have to tell a body before exercising that right?

My experience of having the courtesy to tell my local Council before filming was that every time I did so they made a concerted effort to prevent me filming. Requiring those filming to tell the body in advance could also give the impression that the body has a non-existent legal power to prevent being filmed. I am against any regulations about there being any prior steps to be followed in advance of filming.

“(2)Regulations under subsection (1) may in particular make provision—

(d) about the circumstances in which persons may not carry on such activities, including for enabling a person specified in the regulations to prevent them from doing so in the circumstances specified in the regulations.”

Apart from preventing filming during a part of the meeting where the press and public have been previously excluded I cannot think of any other circumstances in which this would be necessary or desirable (if the aim of these regulations is greater openness and transparency)? If regulations give local Councils any discretionary power to prevent filming (that they currently don’t have) when the meeting is open to the public my concern would be that that would be seen as a regulation that was incompatible with the Article 10 rights to freedom of expression of those wanting to film.

“(3)The Secretary of State may by regulations make provision—


(d) for the creation of offences in respect of any rights or requirements conferred or imposed by the regulations.”

It is unclear about which rights or requirements this is would cover. Clearly if your intention is to extend the provisions of the Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012 then the offences would be if people block or prevent people from exercising their rights under the regulations.

I would like a reassurance that the creation of offences does not include offences covering people exercising their right to film public bodies. Clearly if the regulations include a discretionary power (see 2(d) above) that the body can exercise to prevent filming, this could create an impasse where the body asks them to stop but they believe they have a right to film and refuse to do so.

Bearing in mind all the above, I would either like reassurance (individually on the above points) that my fears about what will be in the regulations and possible new powers granted to public bodies are either unfounded, or for the government to agree to a wider, public consultation on the principles behind the proposed regulations so that before proposing the regulations that you (and your officials) receive a balance of views on this matter rather than just the viewpoints of two bodies that solely represent local government interests on the draft regulations.

It is important that the press can easily hold local democracy in this country to account. I would not want to see either regulations that either make holding public bodies to account by the press unduly burdensome on those attempting to do so, or for public bodies to be granted new powers preventing their public meetings being recorded and the public knowing what they’re doing with their taxes.

I look forward to reading your response to this letter with interest (as I’m sure will my readers).

Yours sincerely,

John Brace

First response received 23rd December via email at 13:48.

from: EEMA_EPICKLES
to: john.brace@gmail.com
date: 23 December 2013 13:48
subject: Thank you for your email to the Rt Hon Eric Pickles MP

Thank you for your email to the Rt Hon Eric Pickles MP, the Secretary of State at the Department for Communities and Local Government.

Our aim is to consider the issues you raise and to respond within 15 working days.

If we feel that the issues raised do not fall within the Department’s responsibilities, we will try to transfer your email to the relevant government department and ask that they reply to you directly.

DCLG Contact Us Team.

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Wirral Council & Filming: Another Chapter in The Long Running Saga

A brief blog post outlining the long running saga regarding filming public meetings of Wirral Council, covering the recent ban by the Chair of the Planning Committee, Eric Pickle’s advice and a brief run down of the history.

Following reporting on the filming ban at Wirral Council’s Planning Committee on this blog last Thursday, the local newspapers have picked up the story (with quotes from Cllr Mooney), Liverpool Echo: Wirral Council defy Government to ban filming and Daily Post: Wirral Council defies government over filming ban. In addition to the local newspaper articles it’s been picked up by Prolific North: Wirral Council defends filming ban on blogger.

So, although the articles are broadly correct I’d like to correct a slight error and make a few clarifications.

Liverpool Echo
“At a meeting of the planning committee on Thursday, a local blogger was again told to stop filming.”

This should read “Shortly before a meeting of the planning committee on Thursday, a local blogger was again told to stop filming.” If it had been at the meeting itself I would’ve posted the footage online, however yes, it has happened before (18th December 2012) on a close 6:5 vote. Back then Cllr Mooney said it would be “just for this meeting” (see video below).

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After a ban on filming happened at a Health and Wellbeing Overview and Scrutiny Committee meeting (on which Cllr Mooney sat) on the 28th March 2013 to discuss the controversial closure of Moreton Day Centre, I sent a letter before claim to Wirral Council (which is the first stage of a judicial review of a decision). I received this response by email back from Wirral Council’s Monitoring Officer Surjit Tour (the same Surjit Tour that Cllr Mooney said told her she could stop filming at meetings).

Tour, Surjit
to
stephengerrard, me
Tue, 2 Apr 2013 16:08:47 +0100

Dear Mr Brace

I am on annual leave until 15 April. I am somewhat surprised by your email and letter given that I have asked you a number of times to meet me to discuss this issue.

Furthermore, there no ban on filming as you and another have been filming a number of committee meetings.

I would suggest that no proceedings are issued until I have had the opportunity to respond. I therefore request an extension of time to 30 April.

I await your response.

Please can you also include Stephen Gerrard in any further response.

Yours sincerely

Surjit Tour

Sent from my HTC Touch Pro 2 on Vodafone
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I was allowed to film meetings until the Planning Committee meeting of 27th June 2013, a further letter before claim (with a proposed reply date of 12th July) was sent to Wirral Council’s legal department and interested parties on the 28th June 2013. At the time of writing I have not received a reply from either Wirral Council or the interested parties.

After I received Surjit Tour’s reply, Eric Pickles issued this press release entitled “Lights, camera, democracy in action” castigating Wirral Council for stopping filming previously on health and safety grounds (a claim that was refuted by the Health and Safety Executive). This led to a wide variety of press coverage (national newspapers (Guardian, Times), various bloggers and others) and this article in the Wirral Globe entitled “Legal review ordered into rules allowing citizens to video Wirral Council committees” (with an unusually high twenty-seven comments).

Last December councillors called for a review. Eight months later I’m still waiting for this review to finish!

I will also make one small response to Cllr Mooney’s comments, I did say that if she as Chair asked a petitioner if they didn’t want to be filmed and they said no I wouldn’t. However she said, “I can’t do that” rejecting what I felt was a reasonable compromise. Despite her assertion that Planning Committee is the only committee where members of the public regularly address it, there are in fact others ranging from the Highway and Traffic Representation Panel, Licensing Act 2003 committee, Licensing, Health and Safety & General Purposes Committee and full Council meetings (public question time). I hope the above sets the record straight somewhat.

The Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012

Interest declaration: The author of this piece earns a living from blogging and filming.
Interest declaration: This is being published on a blog which’ll be affected by the new legislation.
Interest declaration: The author of this piece and editor is an NUJ member.

Yes this is a blog post on the important new The Local Authorities (Executive Arrangements) (Meetings and Access to Information) (England) Regulations 2012.

This comes into effect on the 10th September 2012 (in just under three weeks time at writing this).

Some of the changes it brings on Wirral Council (and its relationship with the press are welcomed) and I summarise below. I’m surprised this is the first I’ve heard of it though.

Change 1

The definition of media (which currently basically covers print (newspapers and magazines) and broadcast (radio, TV etc)) is being broadened. It’ll be expanded so that new media reporters (Internet blogs, tweeting etc) will be covered by the current definition of who a journalist is.

Change 2

There are a variety of changes which make it easier for individual councillors at Wirral Council (presumably the Lib Dem/Tory opposition) to challenge decisions made by the Labour Executive.

Change 3

More transparency on various decisions taken by the Executive that affect more than one council ward, incur new significant spending or new savings.

Change 4

Councils can no longer cite “political advice” as a reason to exclude the public.

Change 5

If a meeting is due to be closed to the public, the council has to justify why it has to be closed and give 28 days notice of such a decision.

Change 6

Some of the legislation on Forward Plans (brought it by the last Labour Government) is being changed.

Quote from Rt Hon Eric Pickles MP (the Conservative Government Minister):

“Every decision a council takes has a major impact on the lives of local people so it is crucial that whenever it takes a significant decision about local budgets that affect local communities whether it is in a full council meeting or in a unheard of sub-committee it has got to be taken in the full glare of all the press and any of the public.

Margaret Thatcher was first to pry open the doors of Town Hall transparency. Fifty years on we are modernising those pioneering principles so that every kind of modern journalists can go through those doors – be it from the daily reporter, the hyper-local news website or the armchair activist and concerned citizen blogger – councils can no longer continue to persist with a digital divide.”

Chris Taggart, of OpenlyLocal.com, which has long championed the need to open council business up to public scrutiny, added:

In a world where hi-definition video cameras are under £100 and hyperlocal bloggers are doing some of the best council reporting in the country, it is crazy that councils are prohibiting members of the public from videoing, tweeting and live-blogging their meetings.

John Brace, Editor said,

“Nearly forty years after the Internet first came into existence, the rights of “citizen journalists” are being enshrined in legislation. Local authorities should not be frightened by the extra scrutiny and transparency this will bring.

As a professional working in this area I welcome some of the changes this will bring on my reporting of Wirral Council, Liverpool City Council (and other local authorities) and I wonder if it will also include other local political bodies such as Merseytravel, Merseyside Fire and Rescue Authority and the soon to be abolished Merseyside Police Authority.

However the existing laws on relationships with the press (print, broadcast, new media and others) need to be adhered to by Wirral Council. The press and the unions such as the NUJ also need to make sure that Wirral Council will “move with the times” and adhere to the new laws and comply with both the spirit and the letter of the new legislation.”

I will be providing a further update to this post once I have had the opportunity to read the legislation and digest its implications in full.