Page 249 - Comparing Media Systems THREE MODELS OF MEDIA AND POLITICS

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The North Atlantic or Liberal Model

PCC – and regulation continues to be discussed, as many argue that
the PCC is ineffective. Important manifestation of Britain’s strong state
tradition include the D-notice system, which restricts reporting of in-
formation that affects “national security,” and the Official Secrets Act,
under which both journalists and public officials can be punished for
“leaks” of privileged information. American journalists were bemused
in 1996 when the Mirror was leaked a copy of the government’s budget,
the day before it was to be presented to Parliament, and returned it to the
government. Prosecutions under the Official Secrets Act are rare, but it
is a part of a wider political culture, partly connected with the strength
of party discipline in the Westminster system, in which inside political
information is not so freely leaked as in the more fragmented American
political system. Libel law is also less favorable to the press in Britain
than in the United States.
It is in the sphere of broadcasting, however, that the differences be-
tween the United States and Britain have been most marked, with Britain
building a strong public service broadcasting system. The BBC was based
on an ideology that rejected “both market forces and politics in favor of
efficiencyandplannedgrowthcontrolledbyexperts”(CurranandSeaton
1997: 114), to which its first director, John Reith, added a Calvinist form
of paternalism in the early years. In 1954 Britain became the first ma-
jor European country to introduce commercial broadcasting; even then,
however, its broadcasting system retained a strong public-service orien-
tation. The BBC and ITV competed for audiences but not for revenue,
with the BBC relying on the license fee and ITV on advertising. And the
Independent Broadcasting Authority (IBA), which regulated commer-
cial broadcasting until the Broadcasting Act of 1990, was a far different,
farstrongerinstitutionthantheFCC.Itwasnotamereregulatoryagency,
but held the license for commercial broadcasting, contracting with the
ITV companies to provide programming and retaining ultimate author-
ity over programming decisions. For this reason it has been common
to refer to the BBC and ITV together as the “public service system” in
British broadcasting. Channel 4 exemplified this unusual structure par-
ticularly well, as a part of the commercial broadcasting system charged
with the public service missions of providing minority programming
and supporting the independent production sector. The Independent
Television Commission (ITC), which replaced the IBA in the 1990s, no
longer holds the broadcast licenses itself, nor is it required to approve
program schedules or advertising, though it still has more influence
over these than the FCC. Like the rest of Europe, British broadcasting,

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