Page 242 - Comparing Media Systems THREE MODELS OF MEDIA AND POLITICS

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The Three Models

of journalism, though in the context of a union rather than a professional
association. The NUJ was badly damaged by the attack on trade unions
during the Thatcher government, though by the end of the 1990s it had
recovered somewhat and 62 percent of British journalists were members
(Henningham and Delano 1998). A branch of the NUJ represents Irish
journalists. Union membership in Canada, as well as membership in the
Canadian Association of Journalists, is spotty, as in the United States;
except in Quebec, where virtually all journalists belong to the Syndicat
des Journalistes. Quebec also has an unusual history of militant contes-
tation by journalists over newsroom power, mainly during the 1960s and
1970s, with efforts to negotiate “professional clauses” protecting jour-
nalists’ autonomy within the news organization (Clift 1981; Saint-Jean
1998).
Formalinstitutionsofself-regulationofthemediaaresimilarlylessde-
veloped in the Liberal than in Democratic Corporatist countries, though
more so than in the Mediterranean region. Ireland has no news council
or press complaints commission. Neither does the United States, where
news organizations have been extremely reluctant to submit to any out-
side interference, with the exception of the Minnesota Press Council,
established in 1970 (perhaps in part a reflection of the Scandinavian
influence on Minnesota’s political culture?). 12 At the other end of the
spectrum is Quebec, which has a relatively strong press council, without
policing powers but with some public financing and with a policy of
taking complaints about all newspapers, whether they have voluntarily
joinedthecouncilornot(Clift1981).OtherCanadianprovinceshaverel-
atively weak voluntary press councils funded by the newspaper industry.
Britain moved in 1991 from a very weak press council to the Press Com-
plaints Commission (PCC), a move intended to avoid continental-style
privacy and right-of-reply legislation. The British tabloids, especially,
have a heavy emphasis on sex scandals, about both public and private
figures. The PCC is clearly stronger than its predecessor, and its presence
is a characteristic the British system now shares with the Democratic
Corporatist countries, though it is still essentially run by the newspaper
industry, “illustrative of the enduring British commitment to ‘hands-off’
self-regulation” (Humphreys 1996: 61).
Journalistic self-regulation in Liberal countries is organized primarily
in an informal way, within individual news organizations. Its evolution

12
An organization called the National News Council existed from 1973–83. It was sup-
ported by a private foundation and one of its functions was to take complaints on
media ethics, but cooperation of news organizations was always limited.

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