Ireland's press regulations, which include an ombudsman and a council of publishers, public citizens, and journalists, are less restrictive than the proposed British version.
With the British government moving ahead on a new media regulator and the UK press in revolt against, some in the country wonder if their neighbors to the west could offer a solution. Could Ireland's model of an official Press Council and ombudsman work in Britain?
Set up by the newspaper industry in response to a government threat to introduce privacy legislation, the 13-member Press Council includes representatives of publishers, members of the public (the appointments are publicly advertised), and one from the National Union of Journalists (NUJ), the leading journalists' union in Britain and Ireland.
Publications that are members, including all of the national newspapers, agree to be bound by its code of conduct, and to recognize the decisions of the council and ombudsman. Membership in the council is not mandatory, but publications that are members are generally subject to lesser damages in the event of successful court actions against them, as a result of the council and ombudsman being "recognized in statute."
The ombudsman, currently John Horgan, a former Labor party politician and journalism professor, adjudicates on complaints from subjects of newspaper stories, and if agreement cannot be found between all parties involved, he can make a ruling or refer the complaint to the Press Council for a final decision.
Seamus Dooley, the Irish secretary of the NUJ, says regulation has not been proscriptive.
The Press Council's code of conduct is more carrot than stick, and starts with a full-throated defense of a free press, saying: "The freedom to publish is vital to the right of the people to be informed. This freedom includes the right of a newspaper to publish what it considers to be news, without fear or favour, and the right to comment upon it."
It goes on, however, to detail what the Press Council sees as the correct way for publications to operate, although the tone is more aspirational than condemnatory. For example, retractions must be printed in a prominent place and ordinary members of the public are entitled to privacy.
"We're quite happy with the way it's going," says retired business journalist Martin Fitzpatrick, NUJ's appointee to the Irish Press Council. "We've never had a hugely contentious press. There is a degree of timidity, and you could fault them for not foreseeing the onset of the financial crisis, but that's not down to regulation."
The high opinion of press regulation is not universally held, however, even in the NUJ's Irish ranks.
"[British] newspapers did horrible things, but they also uncovered horrible things that were done. The effect of regulation will not be the protection of people who, through no fault of their own, find themselves at the center of press attention, it will be the protection of the rich and powerful," says Gerard Cunningham, chairman of the NUJ's freelance branch in Ireland.
(Could Ireland's regulation work in Britain? British papers rebel as UK press regulation moves closer to reality)
Mr. Cunningham, who formerly worked in the US, says the culture of the British press is, for demonstrable reasons, comparable to other countries only in very general terms.
"This is about all about competition," he says. "Maybe The New York Times and, to a lesser extent, The Christian Science Monitor have a national reach, but they're not really competing against a regional metro daily," he says.
This situation with each US metro market having a dominant player is in stark contrast with Britain, where 11 national dailies, a clutch of regional newspapers, a few specialist titles, and an independent national Scottish press all slug it out for the same pound.
"The British market is intensely competitive and they try to break every story. They really do publish and be damned," says Cunningham.
In contrast, a staggering 19 daily papers are available on the newsstands nationwide in Ireland, though nine of these are rarely read imports from the US and UK and three more are regional titles from Northern Ireland. Of the seven popular national newspapers in Ireland, two tabloids are "Celtified" editions of British newspapers and two more are hybrids of British and Irish material. All four are members of the Press Council, though their British equivalents object to press regulation.
Having a regulated press hasn't stopped the Irish government from indicating it may seek further powers, though. In February 2012, the publication by the Irish Daily Star of candid photographs of Britain's Duchess of Cambridge, Kate Middleton, prompted Irish Justice Minister Alan Shatter to consider enacting new, stricter privacy legislation. The government has yet to do so, however.