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Our policies

This page lists the Press Recognition Panel’s (PRP) organisational and external policies.

Board and Executive

Introduction

  1. The Press Recognition Panel (‘the PRP’) has a zero-tolerance policy towards bribery, money laundering, fraud, theft and corruption. The PRP is also wholly committed to the prevention of bribery, money laundering, fraud, theft and corruption and in fostering a culture where these acts are unacceptable. This policy has been developed taking into account the risks the PRP faces and is based on the Ministry of Justice’s six principles: proportionate procedures, top level commitment, risk assessment, due diligence, communication (including training) and monitoring and review. The PRP will take action against those who knowingly partake in fraudulent and corrupt activity, including taking or giving bribes.

Purpose and scope

  1. This policy:
  • defines what is meant by bribery, money laundering, fraud, theft and corruption and gives examples which the Board, Independent members and PRP staff can use to help them recognise such activity;
  • sets out expectations of Board members, Independent members and PRP staff in relation to the prevention, detection and reporting of bribery, money laundering, fraud, theft and corruption and the consequences of non-compliance with this policy;
  • outlines how allegations of bribery, money laundering, fraud, theft and corruption will be investigated and the options open to those who wish to make a wider disclosure; and
  • applies to all Board members, Independent members, advisors, contractors and employees (whether permanent or temporary). The PRP expects others working on its behalf, e.g. consultants and third parties, to comply with this policy.

Bribery

  1. Compliance with this policy is mandatory. Non-compliance for staff is considered to be gross misconduct (and could result in dismissal). Non-compliance for Board and Independent members could result in removal from office. Bribery is a criminal offence under the Bribery Act 2010, which came into force on 1 July 2011. It is defined as “offering, promising or giving someone a financial or other advantage to encourage them to perform their functions or activities improperly, and includes where it is known or believed that the acceptance of the advantage in itself constitutes improper performance. It also includes asking for or agreeing to accept a bribe”. This also includes facilitation payments (small bribes paid to speed up a service) and bribes under duress (blackmail and extortion). There are four offences covered by the Act:
  • bribing another person (where a person offers, promises or gives a financial or other advantage to another person with the intention that the advantage will induce a person to perform a function or activity improperly);
  • being bribed (where a person requests, agrees to receive or accepts a financial or other advantage with the intention that a function or activity is performed improperly);
  • bribing a foreign public official (where a person bribes a foreign public official); and
  • failure of a commercial organisation to prevent bribery (where a person associated with a commercial organisation bribes another person with the intention of obtaining or retaining business for the organisation or an advantage in the conduct of the organisation’s business).

The PRP operates a zero-tolerance policy towards offering and accepting bribes. This includes facilitation payments and bribes under duress.

Money laundering

  1. Money laundering is a criminal offence under the Money Laundering Regulations 2007. In addition, money laundering is also a criminal offence under the Proceeds of Crime Act 2002, Terrorism Act 2000, Anti-Terrorist Crime and Security Act 2001 and Counter-Terrorism Act 2008. Money laundering is defined as “exchanging money or assets that were obtained criminally for money or other assets that are ‘clean’”. The ‘clean’ money or assets do not have an obvious link with any criminal activity. Money laundering also includes money that is used to fund terrorism, however it is obtained. The term ‘laundering’ is used because criminals turn ‘dirty’ money into ‘clean’ funds which can then be integrated into the legitimate economy as though they have been acquired lawfully. The PRP operates a zero-tolerance policy towards money laundering.

Fraud and theft

  1. Fraud is a criminal offence under the Fraud Act 2006. There are many technical definitions of fraud, but we define it as a form of dishonesty, involving either false representation, failing to disclose information or abuse of position, undertaken in order to make a gain or cause loss to another. There are six offences under the Fraud Act:
  • fraud by false representation;
  • fraud by failing to disclose information;
  • fraud by abuse of position;
  • obtaining services dishonestly with intent to avoid payment;
  • possessing, making and supplying articles for use in frauds; and
  • participating in a fraudulent business carried on by a sole trader.
  1. Theft is a criminal offence. The Theft Act 1968 covers the criminal definition of theft and the associated offence of ‘false accounting’. This is defined as where a person dishonestly, with a view to gain for themselves or another or with intent to cause loss to another either:
  • destroys, defaces, conceals or falsifies any account or any record or document made or required for any accounting purpose; or
  • in providing information for any purpose, produces or makes use of any account, record or document, which to their knowledge is or may be misleading, false or deceptive.

The PRP operates a zero-tolerance policy towards fraud and theft.

Corruption

  1. Corruption is defined as “the offering, giving, soliciting or acceptance of an inducement or reward, which may influence the action of any person”. The PRP operates a zero-tolerance policy towards acts of corruption.

Prevention and detection

  1. We expect everyone who works for the PRP to:
  • support the PRP’s public statement on the zero-tolerance policy towards bribery and corruption, and comply with this policy;
  • have, and be seen to have, the highest standards of honesty, propriety and integrity in the exercise of their duties;
  • report all suspected and known cases of bribery, money laundering, fraud, theft and corruption; and
  • assist in any investigation.
  1. The PRP will:
  • publish a statement setting out its commitment to preventing bribery and corruption;
  • undertake a risk assessment of its exposure to potential external and internal risks;
  • ensure that there are suitable levels of internal controls embedded in day to day practices, particularly in relation to financial procedures;
  • ensure that other policies are clear about the PRP’s commitment to anti-bribery, money laundering, fraud, theft and corruption and are followed;
  • ensure that references are checked and necessary due diligence is carried out when recruiting and appointing people and when new suppliers are procured;
  • ensure that Board Members and staff and others who are engaged by the PRP are aware of their duties in relation to the management of interests; gifts and hospitality; and how this policy applies to them;
  • ensure that there are appropriate processes in place to report and investigate concerns about bribery, money laundering, fraud, theft and corruption;
  • ensure an appropriate Whistleblowing policy is in place;
  • provide training and guidance as necessary so that individuals understand their role in relation to preventing bribery, money laundering, fraud, theft and corruption;
  • record and report on allegations received under this policy;
  • take appropriate disciplinary and legal action when necessary, e.g. dismissal, removal from office and termination of contract; and
  • inform the relevant authorities, such as the police, if the circumstances and evidence are appropriate.

Reporting concerns

  1. If there are suspicions that an individual has breached this policy, concerns should be reported as follows:
  • if the concern is about an employee or a contractor – these should be reported to the Chief Executive. If it would not be appropriate to do this, concerns should be reported to the Chair of the PRP;
  • if concerns relate to a Board or Independent member – these should be reported to the Chair; and
  • if concerns relate to the Chair, report these to the Senior Independent Board member.
  1. Concerns should be documented immediately, in as much detail as possible and include all relevant details such as dates, times, places, details of phone conversations, names of those involved etc. An individual should not attempt to carry out an investigation by themselves as this might damage any subsequent investigation.

Investigation

  1. Any allegation of non-compliance with this policy regarding staff or contractors will be investigated by the Chief Executive (unless it would not be appropriate to do this, in which case the investigation will be by the Chair). Any allegation of non-compliance with this policy regarding Board or Independent members will be investigated by the Chair (unless it would not be appropriate to do this, in which case the investigation will be undertaken by the Senior Independent Board Member). If the allegations are sufficiently serious the PRP may inform the relevant authorities (for example, the police or Serious Fraud Office) before any investigation is initiated.
  1. The PRP will:
  • listen to all concerns raised and treat every allegation seriously and confidentially;
  • unless inappropriate to do so, notify the Chief Executive and Chair of all allegations and keep them appraised of the progress of any investigation;
  • get as much information as possible from the reporting individual, including any evidence that may support the allegation;
  • report the outcome of any investigation and make recommendations for any remedial action required to the Board;
  • not ridicule, victimise or discriminate against those who raise a legitimate concern, irrespective of whether it proves to be founded or not;
  • once the investigation is complete, any recommendations will be actioned immediately and these could include, but are not limited to: closing the matter where no wrongdoing is found, referring the matter to the police, or disciplinary action; and
  • notify the person who initially raised the concern of the outcome of the investigation and any remedial action to be taken.

Further concerns following investigation

  1. If an individual is unhappy with the outcome of the initial investigation, concerns can be raised with the Chair, another Board Member, or the Chief Executive. The PRP’s Whistleblowing policy also gives details of how reports can be made to ‘prescribed persons’ (i.e. external agencies).

Monitoring and review

  1. All allegations made under this policy will be reported to the Board, regardless of whether they are founded or not. The identity of the person who raised the concern will be kept confidential. This policy will be reviewed on a regular basis, taking into account new or changes to legislation and regulations as well as best practice.

Reviewed: April 2026 (AGR)

Purpose

The purpose of the Audit and Risk Committee (ARC) is to support the Board in its responsibilities in terms of control, governance and risk management. Its detailed remit is to:

  1. Promote the highest standards of propriety in the use of funds by the PRP, to be satisfied that arrangements are in place to encourage efficiency, effectiveness, proper accountability and value for money for the use of those funds.
  2. Advise the Board on anything that affects the financial health, probity or external reputation of the organisation.
  3. Critically challenge and review the system of internal controls of the PRP so that it complies with all necessary requirements.
  4. Ensure the internal systems within the organisation promote a climate of financial discipline and internal control which will help to reduce the opportunity for financial mismanagement, will satisfy the Board that it will achieve its key objectives and targets and that the organisation is operating in a manner which will make most economic and effective use of resources available.
  5. Ensure that the identification of key risks that threaten the achievement of the PRP’s objectives is carried out and that a register of these risks is maintained.
  6. Ensure that the PRP has a strategy in place to manage risk including monitoring of the satisfactory operation of that risk management strategy, and ensuring arrangements are in place to raise the awareness of risk.
  7. Challenge and hold the Executive to account on aspects of the Committee’s role set out above as appropriate.

The Committee’s duties are as follows:

  1. Review the PRP’s internal and external financial statements, reports and annual accounts ensuring they reflect best practice, comply with appropriate guidance and are produced in a timely manner.
  2. Provide a critical independent opinion on the adequacy of risk management by:
  • commenting on proposals for implementation of risk management and expressing an opinion on their overall adequacy;
  • receiving reports concerning the effectiveness of controls in each area of major risk;
  • commenting annually on the effectiveness of risk management activity in the organisation on the basis of the external audit completion report received and the internal audit annual report, if applicable.
  1. Review the nature and scope of external audit, consider external audit reports and management letters and ensure that the external auditor has the fullest co-operation of the organisation.
  2. Consider and advise the Board on its annual and long-term internal audit programme, if any, and consider internal audit reports reviewing the effectiveness of the PRP’s internal control systems, including changes to the annual audit plan.
  3. Recommend the appointment, fees and termination of employment of the internal audit service if applicable.
  4. Make recommendations to the Board in order that it may be assured that internal controls of the organisation are fit for purpose, effective and give value for money.
  5. Consider any matters referred by the Board, or internal audit service.
  6. Oversee policies on fraud/financial irregularity including any action taken under that policy.
  7. Assess from time to time its own effectiveness and report its findings to the Board.

Membership, Chair, Quorum

  1. The Committee shall consist of up to three members, including a member with financial responsibility. A Committee member can be either a current Board member or Independent member. In light of the size of the PRP, the Chair of the Board may be appointed a member of the Committee, although this is not generally regarded as best practice. One of the members shall be nominated by the Board Chair to chair the Committee and can be either a Board member or an Independent member. In the absence of the Committee Chair, the remaining members present shall elect a member to chair the meeting.
  2. Committee appointments will be made by the full Board, after recommendation by the Chair.
  3. Where a Committee member is also a Board member appointments are made for an initial period of up to three years or until the Member’s appointment to the Board expires; whichever is the sooner. Appointments will then be extendable by additional periods of 12 months after recommendation by the Chair and agreed by the full Board.
  4. Where an Independent member is appointed Chair of the Audit and Risk Committee, the appointment will be subject to the Terms and Conditions of Service for Independent Members.
  5. If the Chair of the Board is not a member of the Committee, the Chair of the Board will be free to attend meetings.
  6. Only Members of the Committee have the right to attend and participate at Committee meetings. However, other individuals such as relevant executives or other advisers considered appropriate by the Chair of the Committee may be invited to attend for all or part of any meeting.
  7. The Committee may ask any or all of those who normally attend but who are not members of the Committee to withdraw to facilitate open and frank discussion of particular matters.
  8. The Committee will be provided with the opportunity to meet internal and/or external auditors, without members of the Executive present to discuss any issues of concern or interest.
  9. The quorum necessary for the transaction of business shall be two members. Members’ attendance via telephone or video-link is permissible for the purposes of determining a quorum.
  10. A duly convened meeting of the Committee at which a quorum is present shall be competent to exercise all or any of the authorities, powers and discretions vested in, as outlined in these terms of reference, or exercisable, by the Committee.
  11. Where the Chair of the Committee considers it appropriate, decisions may be taken by email. An audit trail of decisions taken by email will be maintained.
  12. In the event that a decision is required by vote, where the Committee has the authority to make a final decision, the Chair will have the casting vote. In the instance of a tied vote where a recommendation is being made to the full Board, the outcome of the vote will be reported to the Board.

Access

  1. Representatives of the PRP’s internal and external audit services will have free and confidential access to the Chair of the Audit and Risk Committee.

Frequency and Notice of Meetings

  1. The Committee shall normally meet at least twice a year. The Chair of the Committee may call additional meetings as they deem necessary.
  2. Unless otherwise agreed, notice of each meeting confirming the venue, time and date together with an agenda of items to be discussed and supporting papers, shall be forwarded to each member of the Committee and any other person required to attend, no later than five working days before the date of the meeting.

Minutes of Meetings

  1. A minute of the discussion, decisions and actions of all meetings of the Committee shall be prepared, including recording the names of those present and in attendance.
  2. Minutes of Committee meetings shall be circulated promptly to all members of the Committee once agreed by the Committee Chair.

Accountability & Reporting Responsibilities

  1. The Committee is accountable to the full Board.
  2. The agreed minutes of the Committee meeting will be circulated to the next meeting of the full Board or ex committee, along with a report from the Committee Chair highlighting any issues for the Board’s discussion/consideration as necessary.
  3. The Committee will approve a statement in the annual report about its membership, role and remit for the preceding year timed to support finalisation of the Accounts and the Governance Statement, summarising its conclusions from the work it has carried out during the year.

Other

  1. The Committee shall review its own performance, constitution and terms of reference to ensure it is operating at maximum effectiveness and recommend any changes it considers necessary to the full Board for approval.
  2. The Committee is authorised by the Board to investigate any activity within its terms of reference.
  3. The Committee is authorised by the Board to obtain, at the PRP’s expense, outside legal or other professional advice on any matters within its terms of reference.

Review

  1. These terms of reference form part of the PRP’s Governance Framework and will be reviewed annually.

Reviewed April 2026 (AGR)

Introduction

  1. This policy sets out the Press Recognition Panel’s approach to remunerating Board Members and Independent Members of the Board. The Royal Charter (para 5.3) sets out that ‘The Board may make arrangements to pay or make provision for paying, in respect of any Member, such amounts by way of allowances or gratuities as the Board determines. The amount of any such allowances or gratuities shall be set having regard to the prevailing rates payable to the members of boards of public sector bodies’.

Statement of Policy

  1. Remuneration and minimum time commitment for Board members and Independent Members of the Board will be reviewed annually by the Board.
  2. Any changes to remuneration or the minimum time commitment will be implemented from 1 April the following year.
  3. Remuneration rates and minimum time commitments will be published in the policy and disclosed in the Annual Reports and Accounts. Disclosure will include both the amount and any uplift since the last review.

Future reviews of remuneration

  1. This policy acknowledges that it is not good practice for the Board to set its own remuneration. However, given the size and complexity of the Press Recognition Panel and the obligation to achieve value for money, the Board does not consider that establishing a separate Remuneration Committee, necessitating the recruitment of further Independent Members (and consequent cost), is proportionate at this time.
  2. The Board will keep under review on an annual basis any additional arrangements it wishes to put in place for the purposes of any further reviews of remuneration – including the potential establishment of a Remuneration Committee or undertaking benchmarking.

Pension scheme contributions

  1. PRP Board members and staff are invited to join the PRP’s pension scheme when joining the organisation. Independent members who are paid on payroll for a fixed sum per month will be invited to join the scheme. Independent members not receiving a fixed sum per month will not automatically be invited to join the scheme.

Updated: February 2026 (AGR)

  1. The Press Recognition Panel is committed to eliminating discrimination and encouraging diversity amongst everyone who works with us. We believe that, for our organisation to be successful, we need to work with the most talented and diverse people available. The talents and resources of all individuals will be fully utilised to maximise the efficiency of the PRP.
  2. In delivering our legal responsibilities, including those relating to the recognition of regulators of the press and other news publishers, and as an employer, our aim is to be truly representative of all sections of society. We want everyone who we work with, to feel respected, and able to give of their best. We want everyone whose views are relevant to our work to feel included.
  3. To that end the purpose of this policy is to provide equality and fairness for all in our legal and employment duties, and in the way we conduct our business, and not to discriminate on grounds of any of the protected characteristics of age, disability, gender reassignment, race, religion or belief, ethnicity, sex, sexual orientation, marriage and civil partnership, pregnancy, maternity and political belief. We oppose all forms of unlawful and unfair discrimination.
  4. We will enthusiastically give effect to our obligations arising from the public sector Equality Duty (in light of the fact that the Royal Charter specifies that the PRP’s functions are public functions).
  5. When public authorities carry out their functions, the Equality Act says they must have due regard to the need to:
  • eliminate unlawful discrimination;
  • advance equality of opportunity between people who share a protected characteristic and those who don’t; and
  • foster or encourage good relations between people who share a protected characteristic and those who don’t.
  1. We will ensure we conduct our business in a way which respects all protected characteristics, and that we will engage with all our stakeholders in a way which respects any impacts due to disability or language barrier.
  2. Everyone who works for us, whether part-time, full-time or temporary, will be treated fairly and with respect, and will be helped and encouraged to develop their full potential. The talents and resources of all individuals will be fully utilised to maximise the efficiency of the PRP.
  3. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. In relation to recruitment, appointments will be made solely on merit. We positively encourage applications from people from all sections of the community, from all backgrounds and with a broad range of experience, and this is an integral part of our recruitment process.
  4. To ensure that all those who work for us are treated fairly, we monitor diversity as part of our recruitment process and request that individuals applying for roles with us complete a monitoring form. Providing this information is optional. Information provided will be treated as strictly confidential and will be used for monitoring purposes only. No information will be published or used in any way which allows any individuals to be identified.
  5. Our commitments are:
  • to create an environment in which individual differences and the contributions of everyone are recognised and valued;
  • everyone who works for us and in partnership with us is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated;
  • we will ensure that everyone who works for us is offered training, development and progression opportunities;
  • we will consciously think about the three aims of the Equality Duty as part of the process for decision making and the development of policy options, implementation and review across the organisation;
  • we will instil equality, diversity and inclusion practices that make sound business sense;
  • breaches of our equality, diversity and inclusion policy will be regarded as misconduct and could lead to disciplinary proceedings or legal action; and
  • this policy is agreed by the Board which takes full responsibility for Equality, Diversity and Inclusion issues.
  1. The policy will be monitored and reviewed annually.

Reviewed: February 2026 (AGR)

Purpose

  1. The purpose of this Policy is to set out the responsibilities of those working for and with the Press Recognition Panel (PRP) in respect of offering or receiving corporate gifts and/or hospitality.

Scope

  1. This Policy applies to Board and Independent members, the Executive and to others working with the PRP, including secondees, agency contractors and others employed under a contract of service.

General Principles

  1. The guiding principles governing gifts and hospitality are that:
  • The PRP Board, staff and those working with the PRP may not accept any gifts or hospitality that would reasonably be seen to compromise their personal judgment or integrity; and
  • Any offers of gifts or hospitality received in respect of work with the PRP should be recorded in the Gifts and Hospitality Register.

Gifts

  1. The Board has determined that there would never be circumstances when the acceptance of gifts in any way related to the PRP or its work by either individuals or their relatives would be acceptable. If a gift is offered, it should be politely refused and returned, with an explanation of the PRP’s policy. Details of the offer should be provided to the Executive Administration Manager, who will record details in the PRP’s Gifts and Hospitality Register.

Hospitality

  1. The offering or receipt of hospitality in relation to the PRP or its work may be acceptable provided that it is a normal and appropriate expression of business courtesy. Hospitality may take various forms, from the provision of tea and coffee at meetings to large formal receptions or dinners. Exceptionally, working lunches etc provided at PRP premises or by the PRP at PRP events where meetings last all day need not be reported or registered. All offers of hospitality should be discussed with the Chair or the Chief Executive and recorded by the Executive Administration Manager.

Fees for speeches or other work carried out

  1. It is the PRP’s policy that any decision to speak will be determined on merit; fees will not be accepted. Reasonable expenses connected with a speaking engagement are acceptable. All invitations to speak should be channelled through the Chief Executive to the Chair.

The Gifts and Hospitality Register

  1. All offers must be reported as soon as possible to the Executive Administration Manager, who will record details in the PRP’s Gifts and Hospitality Register. The PRP may require this information to prove that no tax is payable.

Expenses

Scope

  1. This Policy applies to all Board and Independent Members, the Executive, advisers, visitors and staff of the Press Recognition Panel (the PRP).
  1. This policy is designed to ensure cost efficiency and business effectiveness. In making claims for expenses, claimants must apply a test of reasonableness and use the most cost-efficient means of discharging their responsibilities.
  1. The PRP is committed to ensuring that individuals are not disadvantaged due to any factors, including disability or geographical distances, that may prohibit attendance or application, and reasonable expenses will be paid.

Responsibilities

  1. Claimants should submit claims as soon as possible. All claimants must ensure that expenses are submitted within one calendar month and by year-end (31 March). Claims after this period will be paid only in exceptional circumstances.

Expenses

  1. The PRP does not use the services of an authorised travel agent. All travel and hotel bookings should be made directly by the individual who will be reimbursed in accordance with this policy, unless otherwise advised by the Executive Administration Manager (for example, arrangements might be made for travel and hotel accommodation for overnight stays involving all Board Members).
  1. The claimant is expected to take advantage of the best and most cost-effective available rates.

Travel and Subsistence Costs

  1. Individuals are encouraged to choose the least environmentally damaging mode of transport for necessary travel. This includes using the train/bus rather than planes/cars/taxis, due to lower per passenger emissions associated with the former modes of transport.
  2. For necessary travel to attend meetings of the Board or otherwise on the business of the PRP, expenses can be claimed at the following rates:

15.1actual payments for the most cost-effective travel by standard class, a flexible return or the cost equivalent public rail transport. Any requests to travel other than standard class should be forwarded with an explanation of the circumstances to be approved by the Chief Executive. The test of reasonableness will apply

15.2cost is assumed to apply to travel from the claimant’s principal place of residence within the UK. Where this is not the case, the expense claimable would be the lower of the actual cost of travel, and travel from the principal UK residence. Any exceptional circumstances requires approval by the Chief Executive

15.3the same principles applied to rail travel apply also to air travel;

15.4for travel by private car, 55 pence per mile for the first 10,000 miles, 25 pence per mile on each additional mile over 10,000 miles (in accordance with approved HMRC mileage rates as of 6 April 2026), and actual parking fees and congestion charge;

15.5for travel by motorcycle, 24 pence per mile;

15.6for travel by bicycle, 20 pence per mile;

15.7for travel by underground or bus including where oyster card or contactless payment is used, reimbursement of the published fares (where evidence of the journey is not readily available).

  1. When absent from home or attending business meetings of the PRP or otherwise on the business of the PRP, expenditure on subsistence will be reimbursed against receipts up to the following limits:

16.1£10 for qualifying travel of 5 hours or more,

16.2£15 for qualifying travel of 10 hours or more;

16.3£30 for qualifying travel of 15 hours or more; and, where the travel is ongoing after 8pm;

16.4for each night’s absence in respect of accommodation up to £200 per night plus VAT. This must not include any extras such as alcohol or newspapers. These must be paid for separately by the claimant;

16.5any hospitality to third parties must be approved by the Chief Executive and must be in accordance with the PRP’s policy on gifts and hospitality (e.g. hospitality for anyone who is not an employee).

Carer costs or other ‘reasonable adjustments’

  1. Reimbursement of carer costs that enable participants to attend events will be made upon presentation of evidence supporting the claim.
  2. Where ‘reasonable adjustments’ are required to enable a claimant’s participation (whether travel, accommodation or otherwise), the cost of making these will be reimbursed.

Airline Frequent Flyer Schemes

  1. Claimants may retain frequent flyer scheme benefits. However, participation in these schemes must not influence flight selection. The lowest proposed airfare should be taken. Airline club memberships and credit card reward programmes are at the traveller’s expense.

Lost or Missing Receipts / Tickets

  1. For audit purposes, receipts and evidence of the expenditure having been incurred are required for all claims (other than for underground or bus travel, where evidence is not readily available). In the event of lost or missing receipts, the claimant should seek duplicate receipts or produce alternative proof of payment. If no proof of payment is available, refunds will be allowable only if accompanied by a written explanation and approved by the Chief Executive.

Authorisation

  1. All claims submitted must be authorised by the Chief Executive and, in respect of expenses incurred by the Chief Executive, by the Chair or an individual nominated to authorise claims on his behalf.

Notes

  1. The Chief Executive will monitor exceptions to the Policy and report them to the Board periodically.
  2. Claims for subsistence may not exceed the daily limits shown except with the agreement of the Chief Executive. If there is a request for a regular variation in respect of any part of this policy in relation to any claimant, the case will be referred to the Board for a decision, and the policy amended as necessary.

Updated: June 2026

Purpose

The Nominations Committee (NomCo) is an advisory committee and its purpose is to:

  1. Keep under review and make recommendations in relation to the processes for the appointment, re-appointment and appraisal of Board Members and any other non-executives engaged by the PRP e.g. the Independent member of the Audit and Risk Committee;
  2. Make recommendations on appointments and re-appointment processes in line with agreed policy;
  3. Identify and nominate candidates for the approval of the full Board to fill vacancies as and when they arise (operating as a Selection Panel, supplemented as necessary by other Board Members and/or an Independent member);
  4. Nominate for the approval by the full Board the re-appointment of any Board Member at the conclusion of their specified term of office having given due regard to their performance and ability to continue to contribute in the light of the knowledge, skills and experience required; and
  5. Make recommendations to the full Board in relation to extensions and emergency appointments and the disqualification, suspension and removal from office of the Chair and Board Members.

Membership, Chair, Secretary and Quorum

  1. The Committee shall comprise of a minimum of two and a maximum of four members.
  2. The Committee will include the Chair of the Board. The Board may elect an external member to serve as an independent advisory member who is independent of the Board. The Independent Member’s role will be to bring an external perspective to the work of the Committee whilst providing recruitment advice, support and constructive challenge across all aspects of the Committee’s activities.
  3. The Board Chair will chair the Committee. The Chair of the Board shall not chair the Committee when it is dealing with the matter of succession to the chairmanship of the PRP. In this case, the Committee will be chaired by the Senior Independent Board Member.
  4. Appointments to the Committee will be made by the full Board, after recommendation by the Chair. The Members of the Committee will be appointed for a period of up to three years, or until the Member’s appointment to the Board expires; whichever is the sooner. Appointments will be extendable by one additional period of three years.
  5. Only Members of the Committee have the right to attend and participate at Committee meetings. Other individuals such relevant executives or other advisers considered appropriate by the Chair may be invited to attend for all or part of any meeting.
  6. In the absence of the Committee Chair, the remaining members present shall elect a member to chair the meeting.
  7. A member of the Executive shall act as the Secretary of the Committee.
  8. The quorum necessary for the transaction of business shall be two members. Members’ attendance via telephone or video-link is permissible for the purposes of determining a quorum.
  9. A duly convened, quorate meeting of the Committee shall be competent to exercise all or any of the authorities, powers and discretions vested in it as outlined in these terms of reference, or exercisable, by the Committee.
  10. Where the Chair of the Committee considers it appropriate, decisions may be taken by email. An audit trail of decisions taken by email will be maintained by the Secretary of the Committee.
  11. In the event that a decision is required by vote, where the Committee has the authority to make a final decision, the Chair will have the casting vote. In the instance of a tied vote where a recommendation is being made to the full Board, the outcome of the vote will be reported to the Board.

Frequency and Notice of Meetings

  1. The Committee shall meet as required to fulfil its duties.
  2. Meetings of the Committee shall be summoned by the Secretary of the Committee at the request of the Chair.
  3. Unless otherwise agreed, notice of each meeting confirming the venue, time and date together with an agenda of items to be discussed and supporting papers, shall be forwarded to each member of the Committee and any other person required to attend, no later than five working days before the date of the meeting.

Minutes of Meetings

  1. The Secretary of the Committee shall minute the discussion, decisions and actions of all meetings of the Committee, including recording the names of those present and in attendance.
  2. Minutes of Committee meetings shall be circulated promptly to all members of the Committee once agreed by the Committee Chair.

Accountability & Reporting Responsibilities

  1. The Committee is accountable to the full Board.
  2. The agreed minutes of the Committee meeting will be circulated to the next meeting of the full Board, along with a report from the Committee Chair highlighting any issues for Board’s discussion/consideration.
  3. The Committee will approve a statement in the annual report about its membership, role and remit for the preceding year.

Other

  1. The Committee shall periodically review its own performance, constitution and terms of reference to ensure it is operating effectively and recommend any changes it considers necessary to the full Board for approval.

Authority

  1. The Committee has authority delegated from full Board to review and make recommendations in relation to processes for the appointment, re-appointment and appraisal of Board Members. Final decisions in relation to appointments, re-appointments and appraisal are reserved to the Board.
  2. The Committee is authorised by the Board to investigate any activity within its terms of reference.
  3. The Committee is authorised by the Board to obtain, at the PRP’s expense, outside legal or other professional advice on any matters within its terms of reference.

Review

  1. These terms of reference form part of the PRP’s Governance Framework and will be reviewed each year when that framework is reviewed.
Reviewed: February 2026 (AGR)

Introduction

  1. The Press Recognition Panel (the PRP) came into being on 3 November 2014 under the provisions of the Royal Charter on self-regulation of the press.

Frequency of Meetings

  1. The Board shall meet at least five times in each financial year, and frequently enough to discharge its functions. The Board shall revisit the frequency of the Board meetings regularly. The Board will receive monthly organisational and finance updates from the CEO.
  2. An emergency meeting of the Board may be called by the Chair where in their opinion an urgent matter has arisen, or following receipt of a written request, signed by at least two Board Members, setting out the reason why a special meeting is required.
  3. The Board may also hold development and strategy events. The purpose of such events will be to provide an opportunity to reflect more thoroughly on strategy and key issues and also to develop its working practices.

Notice of Meetings

  1. Board meetings will normally be called well in advance and with a minimum of 28 days’ notice. A Board meeting may exceptionally be called at shorter notice. Notice of a Board meeting will be given to Board Members in writing (including by email). Failure to receive notice of a Board meeting will not invalidate that Board meeting or any business transacted at it.
  2. By the end of October each year, a schedule of meetings of the Board (and any committees established by the Board) the following calendar year will be proposed for the Board’s approval.

Agenda and papers

  1. The agenda and papers for Board meetings will normally be circulated at least five clear working days in advance of the meeting by email.
  2. The agenda and papers (other than those relating to items to be discussed in the confidential sessions) for Board meetings will be placed on the PRP’s website at the same time as being provided to Board Members. In the interests of transparency and in order to enable what would otherwise be confidential items to be discussed in public, the Chair may determine —exceptionally — that papers relating to matters scheduled to be discussed in public session should not be published in advance of meetings.
  3. The papers for each meeting shall comprise:
  • an agenda approved by the Chair which shall indicate the matters to be discussed at the meeting (see paragraph 30 below for Order of Business);
  • a copy of the agreed or draft minutes of the last Board meeting;
  • the Chief Executive’s report;
  • the Finance report and
  • such other supporting documents and information relevant to the matters to be discussed as the Chair may think appropriate.
  1. Non-receipt of papers by individual Board Members will not invalidate a Board meeting or any business transacted at that meeting.
  2. Where a meeting of the Board is called at short notice, the Executive shall distribute notice of the meeting and the papers relating to the business to be transacted at the earliest practical opportunity. Papers will be distributed by email.
  3. With the permission of the Chair, papers may exceptionally be tabled at a Board meeting or circulated after the agenda is dispatched.

Executive attendance at meetings

  1. Members of the Executive (and relevant advisers) will normally attend meetings (or the relevant part of meetings) of the Board to support the consideration of specific items of business. On occasion the Executive may be asked to withdraw from all or part of the meeting at the discretion of the Chair.

Other attendees at meetings

  1. Meetings of the Board will be open for public attendance but it will not be permissible for people attending to record or film a meeting or any part of it without the express permission of the Board given in advance.
  2. Members of the public who wish to attend will be asked to notify the Board in advance of their wish wherever practicable so that appropriate arrangements can be made to accommodate the meeting.
  3. The public may be excluded from that part of a meeting which the Chair, or the Board, decides should be held in confidence given the nature of the subject matter, such as where the discussion relates to the personal affairs of an individual or to matters which would attract legal professional privilege, or, exceptionally, where the Board decides that its evaluation of the issues involved could be prejudiced by being held in public.
  4. The Chair may decide to exclude from a meeting any members of the public who disrupt or interfere with the progress of the meeting.
  5. The Board may invite other individuals to attend meetings of the Board, for example the Board may wish to hear a particular stakeholder’s point of view on a matter. The invitation may be for the entire meeting or for a specific item(s); the invitee is not obliged to attend. Any individual attending a Board meeting in this capacity will not be entitled to vote and may be asked to withdraw from the meeting at any point.

Quorum

  1. Any decision made by a properly constituted meeting of the Board satisfying the requirements of these procedure rules shall be deemed to be a decision made by the Board.
  2. In order to ensure that there has been proper input to, and scrutiny of, decisions it is necessary to have a quorum for meetings of the Board. The quorum for meetings of the Board shall be 50% of the Board Members (including the Chair) appointed at that time; when calculating this figure any fractions should be rounded down.
  3. If a Board Member cannot participate in a discussion and/or voting on any matter as a result of a declaration of interest they will not count in the quorum for that item.
  4. If a quorum is not available for the discussion of any matter(s) this will be recorded in the minutes and the decision made will be ratified at the next quorate meeting of the Board.
  5. If a Board meeting becomes inquorate during the course of the meeting any decisions made will be ratified at the next quorate meeting of the Board. If those Members present at an inquorate meeting determine that a decision that falls to be taken by that meeting is of such significance that the decision should be taken by a quorum, that decision may be taken under the deferred decision provision (see below).
  6. All or any of the Board Members may, in exceptional cases, participate in a Board meeting by video conference, telephone (or any communication technique that allows all persons participating in the meeting to hear each other) and this fact will be recorded in the minutes accordingly. Board Members participating in this manner will be deemed to be present at the meeting and shall be entitled to make decisions and to vote and be counted in the quorum.
  7. Written comments on agenda items submitted by a Board Member who is absent will be circulated to those Board Members that are present and read out at an appropriate point in the meeting. This provision does not apply to Members who are not permitted to participate in a matter as a result of a declared conflict of interest.

Chair

  1. The Chair will preside over all Board meetings. In the absence of the Chair, whether this be temporarily on the grounds of a declared conflict of interest or otherwise, a Board Member, chosen from amongst those present, will chair the meeting. It is the responsibility of the Chair or member presiding at the meeting to:
  • decide the order in which Board Members will speak, ensuring that adequate views are sought in order to make informed decisions;
  • determine all matters of order, competency and relevancy;
  • decide which matters are or are not out of order in terms of the meeting;
  • determine whether a vote is required and how it is carried out;
  • maintain order in the meeting;
  • adjourn the meeting, if necessary, for whatever period of time they believe is appropriate.

Declaration of Conflict of Interest

  1. All Board Members must comply with the PRP Board’s Terms and Conditions of Service regarding declaration of conflicts of interest.
  2. Any new interests or changes in interest already registered should be declared as soon as possible and recorded and minuted at the next PRP Board meeting.
  3. Before any item is discussed at a Board meeting, each Board Member must disclose any conflict of interest that they believe may arise in relation to that item. If a Board Member is in any doubt as to whether a particular matter constitutes a conflict of interest, they should disclose it.

Order of Business

  1. The normal order of business at every meeting of the Board shall be:
  • where the Chair is not present and the Chair has not nominated a Board Member to chair the meeting, to select a Member to chair the meeting;
  • to receive any apologies for absence;
  • to consider any declarations of interest;
  • to deal with any matters arising from the minutes of the previous Board meeting in the order in which they appear;
  • to receive a report on any urgent decisions taken between meetings;
  • to consider such business as is set out on the agenda for the meeting;
  • to consider, at the discretion of the Chair, any items of other business.
  1. The order of business may be varied by resolution of the Board at the Chair’s discretion.

Voting

  1. Decisions of the Board will normally be made by consensus rather than by formal vote. Failing consensus, decisions will be made by a vote when:
  • the Chair (or in the Chair’s absence the Member acting in that capacity) feels that there is a body of opinion amongst Board Members at the meeting that disagrees with a proposal or have expressed reservations about it and no clear consensus has emerged; or
  • a Board Member who is present requests that a vote be taken and this is supported by at least one other Board Member; or
  • the Chair feels that a vote is appropriate.
  1. If a vote is taken, the number voting for, against and any abstentions shall be recorded in the minutes. The Chair will cast his/her vote at the same time as the Board. Voting shall normally take place by a show of hands or such other means of assent or dissent as the Chair deems appropriate.
  2. In the event of an equality of votes, the Chair shall have a second and casting vote. The decision will be carried by a simple majority. The Chair’s ruling as to the outcome of such a vote shall be final.

Deferral of Decision

  1. Any Board Member may propose to defer a decision on an agenda item in order that the Board can be provided with additional information to support the taking of that decision, or for any other reason. If this is agreed, the decision to defer, together with the reason for doing so, will be recorded in the minutes of the meeting together with a proposed timescale for returning the matter to the Board for consideration.
  2. A deferred decision may be taken through email correspondence outside of the Board meeting, where this is agreed in the meeting.
  3. All deferred decisions taken between Board meetings will be reported on and reflected in the minutes of the Board meeting subsequent to the decision being taken.

Urgency

  1. During the course of the PRP’s business, matters may arise between scheduled Board meetings that require urgent Board approval or discussion and cannot be postponed until the next convened Board meeting. If the Chair considers the matter to be of a significant nature requiring urgent approval or discussion, arrangements will be made for the matter to be considered via email or at an emergency Board meeting.
  2. Where decisions that would ordinarily be taken at Board meetings have to be made on an urgent basis by email, the following process will apply:
  • In order for a recommendation to be approved, a response must be received from at least 50% of the Board Members appointed at that time. When calculating this figure any fractions should be rounded down. The majority of the responses received must be in favour of the recommendation.
  1. A decision taken under this provision will be reported at the next Board meeting together with an explanation of the reasons for urgency. The decision will be recorded in the minutes of the Board meeting to which it is reported.

Governance and Records

  1. Any point of order alleging a breach of these procedure rules shall be heard immediately. The Chair’s ruling on the point of order shall be final.
  2. Subject to paragraph 13, a member of the Executive will be present at all meetings of the Board and any meetings of a committee of the Board to advise and record any decisions made. The Chair will agree any individual to act as Board Secretary. If the meeting takes place in the absence of a member of the Executive to record any decisions made, a member of the Board must be appointed for this purpose.
  3. The Board Secretary shall be responsible for ensuring that the minutes of the meeting, including a record of any resolution passed by the Board and any committee, are retained. The Chair (or in the Chair’s absence, Board Member acting in this capacity) will be asked to agree the minutes before they are presented to the Board for approval as soon as practicable; once approved the minutes will be signed by the Chair.
  4. Once approved by the Board the minutes will be published on the PRP website, subject to the redaction of any discussion of matters considered by the Board to be confidential, although the decisions taken in the confidential session will be published. The presumption will be for the maximum level of openness and transparency.

Reserved Matters

  1. Certain matters are reserved to the Board for decision and are detailed in the PRP’s Scheme of Delegation and Matters Reserved policy. This does not preclude other matters being referred to the Board for decision.
  2. Where it is a matter of judgement as to whether a matter is reserved to the Board or not, the Chair will make a determination and the matters reserved will be amended or clarified accordingly.
Updated: February 2026 (AGR)

1. Purpose

The Senior Independent Board Member’s role is to:

  • act as a sounding board for the Chair of the Board;
  • serve as an intermediary for other Board Members; and
  • formally manage the appraisal of the Chair’s performance annually.

2. Responsibilities

The Senior Independent Board Member will as necessary and appropriate:

  • act as sounding board for the Chair in any matter which the Chair may determine appropriate;
  • act as a trusted intermediary when necessary between the Chair and other Board Members;
  • convene and chair (once annually, as a minimum) a meeting of the Board without the Chair present to facilitate the annual appraisal of the Chair and on such occasions as are deemed appropriate;
  • report to the Board annually on the fulfilment of the responsibilities of the Senior Independent Board Member;
  • in the absence of the Chair for any prolonged period, perform the functions of the Chair as set out in the Royal Charter, and as set out in all Panel policies and procedures; and
  • chair the Nominations Committee when it is dealing with the matter of succession to the chairmanship of the PRP.

3. Term of Office

  • The term of office will be two years with the possibility of renewal for a further two years subject to Board approval. The maximum term of office will be four years; and
  • appointment or removal from office is a decision reserved to the Board.

Reviewed: February 2026 (AGR)

Basis for appointment

  1. This document sets out the terms and conditions under which your appointment has been made as a Member of the Board of the Recognition Panel established under the Royal Charter on Self-Regulation of the Press. Under the terms of the Charter you are appointed for an initial term of five years and you are eligible for reappointment for a further period of up to three years. The responsibilities and duties of your office and of the Press Recognition Panel (PRP) are set out in the Charter.

Excluded and restricted activities

  1. The Royal Charter places certain restrictions on political activity of Board Members and staff. In relation to Board Members, Schedule 1, 3.3 of the Royal Charter states: ‘In order to ensure the independence of the Board, a person shall be ineligible to be appointed, or to remain as a Member of a Board if he…is a member of the House of Commons, the Scottish Parliament, the Northern Ireland Assembly, the National Assembly for Wales, the European Parliament or the House of Lords (but only if, in the case of the House of Lords, the member holds or has held within the previous 5 years an official affiliation with a political party’.)
  2. It would be inappropriate given the PRP’s status as wholly independent of government for any Board member to engage in active politics. The list of barred activities includes:
  • seeking selection as a candidate for, or being a candidate for, one of the bodies mentioned in the paragraph above, as per the Royal Charter; Membership – or seeking selection as a candidate or prospective candidate – of local authorities (with the exception of parish councils);
  • seeking adoption or selection as a candidate or prospective candidate for election as a Police and Crime Commissioner (current Police and Crime Commissioners may still be considered); and holding any office, performing any role or undertaking any activity within or in relation to a political party which allows or requires the person to speak on behalf of that party or a candidate standing on its behalf in an election or which involves them doing so.
  1. You must:
  • to the best of your ability act in a way which maintains political impartiality and is in line with the maintaining the absolute independence of the PRP, no matter what your own political beliefs are;
  • act in a way which deserves and retains the confidence of everyone with an interest in the PRP’s work; and
  • comply with any restrictions that have been laid down on your political activities.
  1. You must not:
  • act in a way that is determined by party political considerations, or use PRP resources for party political purposes; and
  • allow your personal political views to determine any advice you give or your actions.
  1. Advice is available from the Chair or Chief Executive Officer.

Confidentiality

  1. It is expected that Board members shall not during, or at any time after the termination of their appointment with the PRP use for his or her own purpose or for another’s benefit or disclose to any third-party confidential material and shall use his or her best endeavours to prevent such publication or disclosure. In this context, ‘confidential’ information means any information or matter which is not in the public domain and which relates to the affairs of the PRP or any of its business contacts.

Remuneration and time commitment

  1. Board Members’ remuneration is regularly reviewed in line with best practice. Board members are expected to commit to a minimum of 15 days per annum, and the Chair to a minimum of 50 days per annum.
  2. The Board member with financial responsibility is expected to commit to a minimum of 18 days per annum due to the additional responsibilities that are undertaken in this role.

Expenses

  1. You are eligible to claim expenses in accordance with the PRP’s Gifts, hospitality and expenses policy.

Expression of views

  1. All invitations addressed to Board Members to attend or speak at stakeholder events or to comment on social media in respect of PRP related matters should be referred to the Chair. Care will be taken to ensure that there is appropriate Board representation at events and that Board members are properly briefed in advance of attendance. In the normal course of events, the Chair on behalf of the Board will be the nominated spokesperson.
  2. In relation to requests for meetings with the Board, these should normally be referred to the Chair in the first instance.
  3. All contact with individuals and organisations will be formal and documented. Unless a meeting takes place in the context of Whistleblowing, or freedom of information or data protection legislation create an exemption to disclosure, the default position is that the fact of a meeting having taken place will be subject to public record, even if the content of meetings are held confidentially.
  4. Informal contact by bodies or individuals will be recorded if relevant.
  5. Board members will take care to avoid saying or doing anything on social media that negatively impacts on the PRP’s reputation. Board members will not engage with the media about the PRP without express agreement of the Chair.

Declaration of Registrable Interests

  1. The PRP maintains a register of Board members’ disclosable interests which is a public document published on the PRP’s website. The purpose of the register is to ensure transparency in relation to any interests of Board members, or of their spouses, partners and dependent children.
  2. Board members are required to make a declaration of interests for the purposes of the register immediately on taking up appointment as a Board member and are required subsequently to declare any new matter that is required to be included on the Register as soon as possible after it arises, in accordance with the PRP’s Board rules of procedure.
  3. Board members are asked to review all aspects of their personal and professional life (and those of individuals linked to them both personally and professionally) in order to identify which interests, if any, may be perceived by the public as directly or indirectly influencing or affecting their judgement or as benefiting them. For example:
  • any position of authority in a charity or voluntary body;
  • connection with anybody which contracts with or is likely to contract with the PRP;
  • directorships in public and private companies including non-executive directorships;
  • majority or controlling shareholdings in any undertaking;
  • ownership of any company, business or consultancy; and
  • remunerated employment, consultancy, trade, profession or vocation.
  1. The primary consideration which will determine whether or not an interest should be declared is the reasonable perception of the public rather than whether the interest will have an actual influence or benefit. The latter is relevant only to the issue of resolving potential conflicts and not the decision to declare.
  2. You may be excluded from any discussion or consideration of any matter in which you have disclosed or declared an interest.
  3. It is the duty of each Board member to declare any matter that is required to be included in the register. If a Board member is in doubt as to whether or not a particular matter should be declared, they should discuss the conflict or perceived conflict with the Chair who will provide confidential guidance.

Resignation

  1. Board members may resign from the Board during the period of their tenure. Board members will agree a reasonable departure with the Chair or the Board.

Indemnity

  1. A Chair or Board member who has acted honestly and in good faith will not have to meet out of his or her own personal resources any personal civil liability which is incurred in the execution or purported execution of his or her Board function, save where the person has acted illegally or recklessly. Any costs arising in this way will be met by the PRP. To minimise the risk, Members are expected to act in accordance with the Board’s policies and procedures at all times.

Additional commitments

  1. Board members should not take on any additional appointments that may cause conflict with their current role with the PRP or affect their commitment capacity. Any concerns should be discussed with the Chair.
Updated: February 2026 (AGR)

Basis for appointment

  1. This document sets out the terms and conditions under which your appointment has been made as an Independent Member of a Committee of the Press Recognition Panel (PRP) Board. The period of your appointment and reappointment, responsibilities and duties of your role are set out in your person specification and appointment letter.
  2. Your initial term of appointment will be three years, after which it may be extended on a year-by-year basis by agreement and subject to the approval of the Board.
  3. The period of your appointment and reappointment, responsibilities and duties of your role are confirmed in your person specification and appointment letter.

Restricted activities

  1. It would be inappropriate given the PRP’s status as wholly independent of government for any Independent member to engage in active politics.
  2. You must:
  • to the best of your ability act in a way which maintains political impartiality and is in line with the maintaining the absolute independence of the PRP, no matter what your own political beliefs are; and
  • act in a way which deserves and retains the confidence of everyone with an interest in the PRP’s work.
  1. You must not:
  • act in a way that is determined by party political considerations or use PRP resources for party political purposes; and
  • allow your personal political views to determine any advice you give or your actions.
  1. Further advice is available from the PRP Board Chair (Chair) or Chief Executive Officer.

Confidentiality

  1. It is expected that Independent members shall not during, or at any time after the termination of their appointment with the PRP use for his or her own purpose or for another’s benefit or disclose to any third party confidential material and shall use his or her best endeavours to prevent such publication or disclosure. In this context, ‘confidential’ information means any information or matter which is not in the public domain and which relates to the affairs of the PRP or any of its business contacts.

Remuneration and time commitment

  1. Independent members’ remuneration is reviewed annually in line with best practice. The time commitment will be as agreed in the individual appointment letters and will be reviewed annually.

Expenses

  1. You are eligible to claim expenses in accordance with the PRP’s Gifts, hospitality and expenses policy.

Expression of views

  1. All invitations addressed to Independent members to attend or speak at stakeholder events or to comment on social media in respect of PRP related matters should be referred to the Chair. Care will be taken to ensure that there is appropriate PRP representation at events and that Members are properly briefed in advance of attendance. In the normal course of events, the Chair on behalf of the Board will be the nominated spokesperson.
  2. All contact with individuals and organisations in relation to the work of the PRP will be formal and documented. Unless a meeting takes place in the context of whistleblowing, freedom of information or data protection legislation creating an exemption to disclosure, the default position is that the fact of a meeting having taken place will be subject to public record, even if the content of meetings are held confidentially.
  3. Informal contact by bodies or individuals will be recorded if relevant.
  4. Independent members will take care to avoid saying or doing anything on social media that negatively impacts on the PRP’s reputation. Independent Members will not engage with the media about the PRP without express agreement of the Chair.

Declaration of Registrable Interests

  1. The PRP maintains a Register of disclosable interests which is a public document published on the PRP’s website. The purpose of the Register is to ensure transparency in relation to any interests of Board and Independent Members, or of their spouses, partners and dependent children if relevant.
  2. Members are required to make a declaration of interests for the purposes of the Register immediately on taking up appointment as an Independent member and are required subsequently to declare any new matter that is required to be included on the Register as soon as possible after it arises, in accordance with the PRP Board’s rules of procedure.
  3. Members are asked to review all aspects of their personal and professional life (and those of individuals linked to them both personally and professionally) in order to identify which interests, if any, may be perceived by the public as directly or indirectly influencing or affecting their judgement or as benefiting them. For example:
  • any position of authority in a charity or voluntary body;
  • connection with anybody which contracts with or is likely to contract with the PRP;
  • directorships in public and private companies including non-executive directorships;
  • majority or controlling shareholdings in any undertaking;
  • ownership of any company, business or consultancy; and
  • remunerated employment, consultancy, trade, profession or vocation.
  1. The primary consideration which will determine whether or not an interest should be declared is the reasonable perception of the public rather than whether the interest will have an actual influence or benefit. The latter is relevant only to the issue of resolving potential conflicts and not the decision to declare.
  2. You may be excluded from any discussion or consideration of any matter in which you have disclosed or declared an interest.
  3. It is the duty of each Independent member to declare any matter that is required to be included in the Register. If a Member is in doubt as to whether or not a particular matter should be declared, they should discuss the conflict or perceived conflict with the Chair who will provide confidential guidance.

Indemnity

  1. An Independent member who has acted honestly and in good faith will not have to meet out of his or her own personal resources any personal civil liability which is incurred in the execution or purported execution of his or her Committee function, save where the person has acted illegally or recklessly. Any costs arising in this way will be met by the PRP. To minimise the risk, Members are expected to act in accordance with the Board’s policies and procedures at all times.

Additional commitments

  1. Independent members should not take on any additional appointments that may cause conflict with their current role with the PRP or affect their commitment capacity. Any concerns should be discussed with the Chair.

Updated: June 2026

Finance

  1. General

1.1 Established by Royal Charter, the Press Recognition Panel (‘the PRP’) was granted funds from the Exchequer to enable the Board to commence its operations and fulfil its purpose for the first three years of operation. The grant of such monies was made in accordance with the general principles of Managing Public Money, and the PRP continues to ensure that it takes into consideration this guidance whilst in receipt of public funds.

1.2 The Chief Executive is designated as the Accounting Officer for the PRP and is personally responsible and accountable to Parliament for:

  • safeguarding the public funds for which she has charge; and
  • ensuring propriety and regularity in the handling of those public funds.

1.3 This document establishes the financial control framework for the PRP. It is set by the Board and is applicable to everyone who works for the PRP, to ensure that the Accounting Officer can undertake her duties in accordance with the law and the general principles of Managing Public Money, in order to achieve probity, accuracy, economy, efficiency and effectiveness. Failure to comply with the Finance policy could result in disciplinary action.

  1. Roles, responsibilities and delegation

2.1 The Accounting Officer exercises financial supervision and control by:

  • defining specific financial responsibilities;
  • agreeing the financial strategy; and
  • defining and approving financial procedures and systems.

2.2 The Accounting Officer is personally accountable to Parliament for the stewardship of the PRP’s funds, for the good management of the organisation, and for ensuring that the PRP meets its obligation to undertake its role and functions within the financial limits set. The Accounting Officer is responsible for signing off the PRP’s annual report and accounts.

2.3 The Accounting Officer will, as she deems appropriate, delegate detailed responsibilities to other staff (in writing) within an approved scheme of delegation.

2.4 The Accounting Officer must ensure that all of the Board and staff are notified of and understand their responsibilities within these financial procedures.

2.5 The Accounting Officer is responsible for:

  • implementing the PRP’s financial policies and for coordinating any corrective action;
  • maintaining an effective system of internal control including ensuring that financial procedures and systems are prepared and documented;
  • ensuring that sufficient records are maintained in order to ensure, with reasonable accuracy, the financial position of the PRP at any time;
  • maintaining a scheme for charging fees to Regulators in relation to the functions of recognition and cyclical review, which will subsequently be approved by the Board and consulted on publicly. The aim of the scheme is that the PRP will recover its full costs in determining applications for recognition and for conducting cyclical reviews, as appropriate. Paragraph 11.3 of the Royal Charter refers; and
  • ensuring the provision of financial advice to the Board.

2.6 The Accounting Officer is responsible for the procurement of goods and services including:

  • reviewing the procurement policy;
  • ensuring goods and services are procured in accordance with best practice at the best levels of value for money and with due regard to the proportionate value of goods and services that are being procured.

2.7 Staff are responsible for:

  • the security of the property of the PRP;
  • avoiding loss;
  • exercising economy and efficiency in the use of resources;
  • conforming with the requirements of this policy, any limitations on delegation of authority to them and financial policies and procedures;
  • ensuring that budget allocations are not overspent and that planned and actual expenditure takes full account of the need to achieve value for money in terms of efficiency, effectiveness and economy;
  • ensuring that potential significant variations from profiled budgets are drawn to the attention of the Chief Executive so that she, and the Board if appropriate, can consider whether the available resources can be used cost-effectively to further the work of the PRP or to determine what additional action needs to be taken; and
  • preventing, reporting and detecting fraud and corruption and ensuring that all PRP colleagues share this responsibility.
  1. Financial Systems

3.1 The Accounting Officer is responsible for the maintenance of appropriate financial systems in order to allow the Chair and Board to carry out their financial obligations. The financial systems must be properly described and kept updated.

3.2 The Accounting Officer will ensure maximisation of separation of duties so that individuals are protected from exposure to undue influence, unfair criticism or allegation.

3.3 The Accounting Officer will ensure that suitable back-up arrangements and/or reserve facilities are in place and that when required they can be invoked with sufficient speed to ensure that the operation and integrity of the services are maintained.

  1. Business planning, budgets, budgetary control and monitoring

4.1 The Accounting Officer will compile and submit to the Board for consideration an annual proposed budget to finance the activities in the PRP’s work plan.

4.2 The Accounting Officer may delegate the management of a budget to permit the performance of a defined range of activities. This delegation must be in writing and be accompanied by a clear definition of: the amount of the budget; the purpose(s) of each budget, individual responsibilities and the provision of regular reports.

4.3 The Accounting Officer, with the assistance of the finance support provider (or equivalent) will devise and maintain systems of budgetary control and expenditure forecasting.

4.4 Budget holders are responsible for ensuring that expenditure is kept within budget. If budgets are exceeded then the reasons for this should be reported to the Accounting Officer, together with any proposed remedial action.

4.5 In accordance with para 11.9 of the Royal Charter, the Chair will appoint one Board Member to take specific responsibility for reporting to the Board on the management of the finances of the PRP. The Board member with this responsibility may be the Chair of the PRP’s Audit and Risk Committee. The finance support provider will meet the Board Member as required to discuss the PRP’s finances in detail. The Accounting Officer will also attend these meetings.

  1. Annual accounts

5.1 The financial year for the PRP is the period from 1 April to 31 March each year.  The Accounting Officer will prepare annual accounts for each financial year in accordance with the Financial Reporting Manual issued by HM Treasury.

5.2 In accordance with Royal Charter, the Board must send a copy of the statement to the Comptroller and Auditor General (C&AG) as soon as practicable after the end of the financial year (para 12.2).

5.3 In accordance with any necessary arrangements made between the Comptroller and Audit General and the Press Recognition Panel, the C&AG will examine, certify and report on the statement each year (para 12.3). The PRP is required to lay a copy of the certified statement and the C&AG’s report before Parliament (para 12.4).

  1. Banking Arrangements

6.1. The Accounting Officer is responsible for managing the PRP’s banking arrangement within the parameters set by the Board.

6.2 The PRP is able to earn any interest on its balances – the PRP’s Investment policy provides further advice on the PRP’s policy on all investments.

6.3 All payments for invoices, for the salaries and expenses of staff and for the salaries and expenses of the Board will be paid by way of the Banking Automated Clearing Service (BACS). Adequate control mechanisms must be in place with the maximum practicable separation of duties for each payment mechanism.

  1. Payroll

7.1 The Accounting Officer is responsible for managing the payroll including making payments on agreed dates.

7.2 The Accounting Officer must be satisfied that proposed payments are supported by appropriate contractual evidence which have been appropriately authorised before confirming payment of the proposed payroll. The Accounting Officer will carry out such periodic checks to ensure that on-going payments are correct and due and these should be evidenced.

  1. Delegation of authority

8.1. The Board delegates authority to the Chair to agree an increase to any additional hours required by the Chief Executive (within the agreed budgeted annual staff remuneration cost) to support the Board in meeting its Charter obligations. The Board will be provided with an annual update for audit purposes.

8.2 The Board delegates authority to the Chief Executive to agree an increase to any additional hours required by the Executive staff (within the agreed budgeted annual staff remuneration cost) to support the Board in meeting its Charter obligations. The Chief Executive will provide an annual update for audit purposes.

8.3 The Accounting Officer will determine the level of financial delegation to budget holders, within the overall scheme of financial delegation approved by the Board (attached at Appendix 1).

8.4 The limits are in respect of individual transactions within the budget and apply to authority to commit expenditure against the budget and to enter into formal contracts (as opposed to being centred on payments). The limits will be reviewed each year and agreed before the start of the year to which they relate. The limits apply to designated roles and therefore any changes to role holders do not require individual re-authorisation.

8.5 The Executive Administration Manager (or equivalent) will maintain an up-to-date record of authorised signatures and financial authorities on behalf of the Accounting Officer.

  1. Procurement

9.1 The PRP is committed to achieving value for money, in terms of quality and price, for all of its procurement activity. In order to achieve this, the PRP will endeavour to clearly communicate its requirements and evaluation criteria, as an informed purchaser, and to establish levels of competition appropriate to the size and complexity of the purchase in accordance with the procurement policy.

  1. Payment of invoices

10.1 The Accounting Officer is responsible for ensuring that a system of verification, recording and payment of all amounts payable is in place. The system shall provide for certification that the goods or services invoiced were supplied in the time and manner and to the standard ordered before correct payment is made.

10.2 All properly authorised and approved invoices should be routinely paid within supplier terms or 30 days of receipt unless a longer payment term has been agreed or there is a dispute. The PRP will aspire to pay all properly authorised and approved invoices within 10 working days; the PRP abides by the provisions of the prompt payment code.

10.3 Budget holders are responsible for ensuring that invoices received for checking are returned promptly to the Accounting Officer.

10.4 The Accounting Officer will ensure that payments are made to creditors by way of the Banking Automated Clearing Service (BACS). Adequate control mechanisms must be in place with the maximum practicable separation of duties for each payment mechanism.

  1. Management and Disposal of Fixed Assets

11.1. The Accounting Officer is responsible for maintaining an asset register of all capital assets leased or owned by the Panel. In addition, the finance support provider will ensure that an inventory is maintained of all valuable, attractive and/or portable assets that belong to the PRP. In respect of fixed assets, items are capitalised where the purchase price exceeds £2,000.

  1. Internal Audit

12.1 The PRP Audit and Risk Committee has determined that an internal audit service is not currently required, and this position is being kept under review.

  1. External Audit

13.1 The National Audit Office (NAO) conducts the PRP’s annual external audit in accordance with International Standards on Auditing (UK and Ireland) (ISAs (UK and Ireland)), so as to enable the Comptroller and Auditor General to give an opinion on the financial statements.

13.2 Further details of the scope of the audit, as well as the NAO’s and PRP’s respective responsibilities are set out in the letter of engagement, which is available in the correspondence section of the website.

13.3 The Audit and Risk Committee considers an audit planning report from NAO ahead of the start of the external audit each year. This document explains:

  • how the NAO, on behalf of the Comptroller and Auditor General, plans to audit the financial statements, including how the NAO will address significant risks of material misstatement to transaction streams and balances;
  • the planned timetable, fees and audit team; and
  • matters which NAO are required to communicate to the PRP under the auditing standards, including the scope of the audit, respective responsibilities, and how the NAO maintains independence and objectivity.
  1. Regularity, propriety and fraud

14.1. Board Members and staff of the PRP have a responsibility for ensuring compliance with Parliamentary requirements on the control of public expenditure and financial regularity and propriety.

14.2 Regularity is the requirement for all spending to accord with the relevant legislation, the relevant delegated authority, and the general principles of Managing Public Money.

14.3 Propriety requires spending to respect Parliament’s intentions, conventions and control procedures, including any laid down by the Committee of Public Accounts.

14.4 In dealing with fraud, corruption or other financial irregularity the Chief Executive, as Accounting Officer, is responsible for ensuring that a robust system of internal control is in place within the PRP which includes effective anti-fraud and corruption controls.

14.5 Board Members and staff have responsibility to prevent, report and detect fraud and corruption.

14.6 Anyone who suspects fraud or other financial irregularity must immediately report the matter to the Accounting Officer. In the event that the matter concerns actions by a Board member, the report should be made direct to the Chair of the Board. Concerns about the Chair should be made to the Senior Independent Board member. The PRP has a separate Anti-bribery, money laundering, fraud, theft and corruption policy which should be referred to as appropriate.

  1. Special Payments Process

15.1 Special payments:

  1. all special payments require the approval of two of either the Chair of the Board, the Board Member with Financial Responsibility or the CEO, and are reported to the full Board at the next meeting.

15.2 Losses:

  1. ending the loss and attempting to recover it;
  2. establishing the cause and taking corrective action;
  3. correcting any weakness in controls;
  4. establishing responsibility and whether the loss was caused by inadequate supervision, negligence or misconduct, and taking appropriate action;
  5. ensuring any lessons are picked up and applied in future; and
  6. reporting the loss and action taken to appropriate bodies, including the Board.

Appendix 1

Scheme of financial delegation

The Chief Executive is the PRP’s designated Accounting Officer and holds accountability for the PRP’s budget.

Non-payroll expenditure

In order to provide adequate scrutiny of financial decisions, the following limits define levels above which financial decisions need to also be agreed by the Board, for non-payroll expenditure:

  • Where budgeted – £25,000
  • Where unbudgeted – £5,000

Corporate Credit cards – overall company monthly limit £11,250

The Chair and the Executive Administration Manager hold corporate credit cards, with a maximum monthly limit of £2,500. The Executive Administration Manager has financial delegation limits for subscriptions and office sundries and the Chief Executive approves the remainder (in accordance with limits in the budget) in advance.

All credit card purchases must be approved in advance by the Chief Executive regardless of amount. The PRP credit card details must not be stored on any online payment portals/wallets and must be removed immediately on confirmation of receipt for all transactions undertaken on behalf of the PRP.

Payroll costs

Any changes to payroll costs are agreed by the Chief Executive (and Chair, if appropriate).

Payments from bank accounts

All payments from the Panel’s bank accounts (including transfers between the Panel’s bank and fixed term deposit accounts) must be authorised on the bank by any two of the following:

  • the CEO
  • the Chair
  • the Board member charged to take specific responsibility for reporting to the Board on the management of the finances of the Recognition Panel under the Charter.

Updated: February 2026 (AGR)

Scope

  1. This policy applies to the investment of all funds of the Press Recognition Panel (the PRP).
  2. The PRP is required to maintain a minimum accessible cash reserve in order to provide a cushion against the impact of unforeseen payments. All remaining balances arising from the management of cash flow will be invested in approved investment institutions to maximise investment earnings. The institutions must be subject to the Financial Conduct Authority (FCA) regulations.
  3. The investments will be managed by the Accounting Officer (or equivalent), or another officer appointed by the PRP to act as Investment Officer, who will strive to invest with the judgement and care that prudent individuals would exercise in the execution of their own affairs, to maintain the safety of principal, maintain liquidity to meet cash flow needs and to provide competitive investment returns for the PRP.
  4. From time-to-time investments may be managed through external professionals. These must be managed in a manner consistent with this policy.

Security

  1. The security of the principal is the foremost objective of all investments. Investments will be managed in a manner that seeks to ensure the security of capital.

Credit Risk

  1. The PRP will minimise credit risk and the risk of loss due to the failure of the financial institution by dealing only with financial institutions, brokers/dealers, intermediaries, and advisors who are regulated by the Financial Conduct Authority.

Interest Rate Risk

  1. The PRP will minimise the risk of interest-bearing investment redemption penalties by planning the maturity of deposits so that they meet the cash flow requirements for day-to-day operations avoiding the need to cash in prior to maturity.

Currency Risk

  1. The PRP will eliminate the risk of loss by investing in the United Kingdom in sterling.

Liquidity

  1. The liquidity of investments will be organised to meet all operating requirements that may reasonably be anticipated. This will be accomplished by structuring the portfolio so that deposit maturity is linked to the cash needed to meet anticipated demands.

Standards of care

Prudence

  1. The Board has authority to select any second bank, and the Chief Executive Officer has authority to manage any transactions between the savings and deposit accounts. Investments will be made with judgement and care for investment and not for speculation and reflect the security of capital as well as the income expected. The PRP recognises that no investment is totally free from risk.
  2. Any person delegated responsibility by the PRP who acts in accordance with written procedures and this investment policy will be relieved of personal liability for the performance of these investments.

Ethics and conflicts of Interest

  1. Individuals involved in the investment process must avoid any activity that might conflict with the proper execution and management of the investments, or that could impair their ability to make impartial decisions. Employees and investment officials must disclose any material interests in financial institutions with which they conduct business.

Delegation of Authority

  1. Authority to manage the investments is delegated to the Chief Executive Officer or another officer specifically appointed by the PRP who will act in accordance with this investment policy. No person may engage in an investment transaction except as provided under the terms of this policy. The Chief Executive Officer will be responsible for establishing controls to regulate the activities of other officials to whom this function is delegated by the Board.

Checks and balances

  1. The following guidelines have been established to enhance the integrity and transparency of the Panel’s internal procedures for investing the Board’s funds and for accounting for those investments.
  2. Any designated officer acting as Investment Officer(s) will be authorised, under the Scheme of Delegation for Financial Management, to transact investment business on behalf of the Board.
  3. All investment confirmations will be sent directly to the Chief Executive Officer where transaction details will be compared and verified against internal records. The Finance Director (or equivalent) will review all investment transactions subsequent to execution. All journal entries relating to investments will be countersigned by the Chief Executive Officer, on the basis that she has not been involved in conducting the transaction.

Investment transactions

Internal Controls

  1. The Accounting Officer is responsible for establishing and maintaining an internal control structure that will be reviewed annually with the PRP’s external auditors. The internal control structure will be designed to ensure that the assets of the Board are protected from loss, theft or misuse and to provide reasonable assurance that these objectives are met. The concept of reasonable assurance recognises that the cost of control should not exceed the benefits.

Eligible Investment

  1. The following list represents the current range of investments which are authorised for the investment of funds.

18.1Deposits — The Board may invest funds regulated by the FCA to meet short-term liquidity needs in instant access saving accounts and in fixed-term deposits. The maturity of these will vary to coincide with expected cash demands. Any deposit investment is restricted to at least High Grade ratings by relevant ratings agencies.

18.2Bonds — The Board may only invest in Bonds which are issued by the UK government and purchased on the Stock Exchange or directly from the Treasury. Bonds may also be purchased through authorised dealers and banks.

18.3Shares or other securities — The Board will not invest in either public or private equity or other securities.

Investment Restrictions and Prohibited Transactions

  1. The investment of the PRP’s funds will be subject to the following restrictions:
  • Borrowing for investment purposes is prohibited.
  • Investing in shares or other securities is prohibited.
  • Investment in any instrument, which is commonly considered a “derivative” investment (e.g. options, futures, swaps, caps, floors, and collars), is prohibited.

Performance Review and Reporting

  1. The Chief Executive Officer will prepare an investment report for Board Member with responsibility on behalf of the Board for financial matters that will provide an analysis of current investments and transactions over the reporting period where appropriate. The report will include a listing of individual investments held at the end of the reporting period. The report will be presented to the full Board annually.

Record Keeping and Safekeeping

  1. The Chief Executive Officer will be responsible for ensuring all investment transactions are recorded and for securing all documents relative to such transactions.

Policy Considerations

  1. The Chief Executive Officer will review the Investment policy periodically and recommend all necessary changes to the Board Member with responsibility on behalf of the Board for financial matters, and for onward approval by the full Board.
Updated: February 2026 (AGR)
  1. The Chief Executive is the PRP’s designated Accounting Officer and holds accountability for the PRP’s budget. To support this role, the Board has established levels of financial accountability, above which financial decisions need to be agreed with the Board, as set out in the PRP’s Finance policy.
  2. For items under £5,000, purchasing decisions are at the discretion of the Accounting Officer who is responsible for ensuring value for money.
  3. For items over £5,000, we will seek two written quotes from suppliers based on a clear specification.
  4. For items over £25,000, we will seek three written quotes from suppliers based on a clear specification. Our decision will be based on value for money which might include an unbiased consideration of the following factors:
  • price;
  • ability to deliver the required service quality and timescales;
  • warranty and guarantees;
  • experience;
  • reputation; and
  • sustainability and ethical considerations.
  1. The written quotes and final recommendation will be shared with the Board Member with specific responsibility for reporting to the Board on the management of the finances of the PRP, and the paperwork will be retained for the audit trail. Where appropriate, we reserve the right to advertise and selection criteria will be developed against which to assess bids. In the event that there are compelling documented reasons not to seek three written quotes, we will record this decision in writing.
  2. In the very unlikely event that we need to procure a very large project valued in excess of £118,000, our default position would be to use the UK’s e-notification service ‘Find a Tender’ as a matter of good practice. We will seek legal advice as necessary.
  3. We may select a preferred supplier directly where the service required:
  • is highly specialist and we cannot identify potential alternative suppliers;
  • is highly commercially confidential and we do not wish to release information about our need for the service to the market; and
  • extends or relies on knowledge from a relevant previous collaboration with one particular supplier.
  1. In these cases, we will take reasonable steps to establish that the supplier’s costs are acceptable e.g. by comparing with day rates from other similar businesses where this is practicable and record and retain that information in the form of a file note.
  2. We will clearly document the circumstances when extending a previously commissioned service with a supplier to carry out a related but distinct piece of work is preferable to re-procuring (this will generally be in circumstances where the time lapse is for a defined period i.e. not more than 6 months from the end of the previous contract).
  3. We will not select a supplier based on the location of a supplier only or requiring delivery/response within timescales that would restrict the supplier market. Geography may end up being a factor, but it will never be a pre-requisite. We will decide and record what criteria are important to us, to allow us to decide which supplier offers the best value for money.
  4. We will not inadvertently discriminate against small suppliers, or those based outside London, by proactively looking at smaller suppliers and suppliers based outside of London to ensure the widest range.
  5. Third party suppliers and contractors will be asked to complete a Supplier checklist to disclose AI to mitigate supplier risk – Back Office\Contracts\(DRAFT) Supplier Checklist.docx.
  6. The PRP’s annual turnover falls below the £36m level which is the threshold under the Modern Slavery Act 2015 for producing an annual statement under the Act. The PRP is fully committed to preventing slavery and human trafficking in our supply chain. Our assessment process includes due diligence checks of the supplier’s reputation and respect for the law, compliance with health, safety and environmental standards.
  7. The Chief Executive’s limit is £25,000 for budgeted spend and £5,000 for unbudgeted spend. Unless specific authorisations have been agreed by the Board, levels above this need sign off by the Board. The final purchasing decision rests with Chief Executive and/or Board (depending on the level of spend).
  8. The Chief Executive periodically reviews the contracts with the suppliers to ensure that they remain fit for purpose and continue to provide value for money.
Updated: April 2026 (AGR)

Risk policy purpose

  1. This policy is a formal acknowledgement that the Board of the Press Recognition Panel (PRP) is committed to maintaining a strong risk management framework. The aim is to ensure that the PRP makes every effort to manage risk appropriately by maximising potential opportunities whilst minimising the adverse effects of risks. The policy will be used to support the internal control systems of the organisation, enabling the PRP to respond to strategic, reputational and operational risks regardless of whether they are internally or externally driven.

Risk policy objectives

  1. The risk policy objectives of the PRP are to:
  • confirm and communicate the PRP’s commitment to risk management;
  • establish a consistent framework and protocol for determining appetite for and tolerance of risk and for managing risk;
  • assign accountability to identified individuals for risks within their control; and
  • provide a structured process for risk to be considered, reported and acted upon within the PRP.

Risk policy statement

  1. The Board and executive management of the organisation believe that sound risk management is integral to both good management and good governance practice.
  2. Risk management forms an integral part of the PRP’s decision–making and is incorporated within strategic and operational planning.
  3. Risk assessment will be conducted on all new activities and projects to ensure that they are in line with the PRP’s objectives. Any threats or opportunities arising will be identified, analysed and reported at an appropriate level.
  4. A risk register covering the key strategic, delivery, reputational and organisational risks will be a live document and formally reported on to the Board on a biannual basis and more frequently where risks are known to be volatile. A more detailed operational risk register will be maintained for specific projects where this is considered appropriate, taking account of the impact of potential risk and the cost benefit of the exercise.
  5. Staff will be provided with adequate training on risk management and their role and responsibilities.
  6. The PRP will regularly review and monitor the effectiveness of its risk management framework and update it as considered appropriate. Reports will be made to the Board biannually of continuing and emerging high concern risks and those where priority action is needed to effect better control.

Roles and responsibilities

  1. The role of the Board:
  • To ensure that a culture of risk management is embedded throughout the PRP.
  • To set the level of risk appetite and risk tolerance for the PRP in specific circumstances.
  • To communicate the PRP’s approach to risk and set standards of conduct expected of staff.
  • To ensure risk management is included in the development of business plans, budgets and when considering strategic decisions.
  • To approve major decisions affecting the PRP’s risk profile or exposure, in line with the Board’s matters reserved and scheme of delegations.
  • To satisfy itself that less fundamental risks are being actively managed and controlled.
  • To review regularly the PRP’s approach to risk management and approve any changes or improvements to processes and procedures as necessary.
  • To receive reports from the external auditors (National Audit Office), the Audit and Risk Committee, external consultants and any other relevant parties and to make recommendations to the Board as necessary.
  1. The role of the Audit and Risk Committee (ARC):
  • The purpose of the ARC is to support the Board in its responsibilities in terms of control, governance and risk management. The ARC reports to the Board on internal controls and emerging issues, in addition to overseeing the external audit. The detailed remit is set out in the ARC Terms of Reference.
  1. The role of the Chief Executive Officer:
  • To ensure that the risk management policy is implemented.
  • To manage the risk register.
  • To anticipate and consider emerging risks and to keep under review the assessed level of likelihood and impact of existing key risks.
  • To provide regular and timely information to the Board on the status of risks and their mitigation.
  • To implement adequate corrective action in responding to significant risks.
  • To learn from previous mistakes and to ensure that contingency plans are sufficiently robust to cope with high-level risk.
  1. The role of the Accounting Officer: The Chief Executive, as the PRP’s Accounting Officer, will also have due regard to the general principles described in paragraph 3.3 of Managing Public Money in relation to key aspects of risk management, including:
  • to take a balanced view of the organisation’s approach to managing opportunity and risk commensurate with the organisation’s risk appetite;
  • have trustworthy internal controls to safeguard, channel and record resources as intended;
  • have practical documented arrangements for controlling or working in partnership with other organisations, as appropriate;
  • use management information systems to gain assurance about value for money and the quality of delivery and make timely adjustments;
  • use internal and external audit to improve its internal controls and performance; and
  • sign the governance statement within their Annual Report and Accounts.
  1. The role of staff: All colleagues are responsible for managing project-specific operational risks and for ensuring that risks are reported upon in a timely fashion through designated lines of reporting.

Interaction with other policies

  1. Risk management forms part of the PRP’s system of internal controls and should be read in conjunction with the policies and detailed controls procedures specified in our Finance policy and related policies. In addition, the PRP expects to meet minimum standards required by legislation and good practice in operational areas including data protection, financial management and reporting and governance.
  2. The risk of falling short of these standards is mitigated as far as possible by ensuring that appropriate policies and procedures are adopted in each of these key areas and stringent internal controls are in place. Where necessary, external advice will be sought to supplement internal expertise.
Updated: April 2026 (AGR)

Principles overall

  1. The following principles in relation to delegation are to be applied:
  • The Board may delegate any of its functions (other than those which the Royal Charter itself requires the whole Board to take) to the Chair, an individual Board Member, a committee or to a member of the executive. Any such delegation will be recorded as a formal resolution of the Board. Regardless of any delegation, the Board remains ultimately accountable for and must take corporate responsibility for action taken.
  • The Board delegates to the Chief Executive Officer, the discharge of all statutory or general legal obligations (such as those arising as an employer or in relation to the Data Protection Act 2018) other than any matter reserved to the Board; and any matter delegated to a committee of the Board. Detail of the delegation of functions are set out in the scheme of delegation.
  • The Chief Executive Officer, in consultation with the Chair, may delegate the discharge of some of the functions to one or more members of staff. The Chief Executive Officer will keep a list of such delegations.
  • The Board may make delegations or vary, revoke or add to existing delegations. Any delegation made by the Board may be limited or made subject to any conditions, for example, the Board may delegate a function only for a limited period of time or for a particular matter.
  • The Board delegates to its committee(s) the discharge of those functions that fall within their respective terms of reference other than any matter reserved to the Board.
  • Unless the Board imposes a condition to the contrary, a committee of the Board may delegate the discharge of a function to a sub-committee or a named Board Member or executive, subject to any conditions imposed by that committee.
  • The Board authorises the Chair or the CEO to legally bind the PRP into any contractual arrangement on its behalf.
  • The CEO has accountability for the PRP’s budget as Accounting Officer. The Board supports the Accounting Officer in this role by overseeing expenditure decisions above £25,000 of budgeted spend and £5,000 of unbudgeted spend.
  • The Board may discharge a function itself even though it has delegated the discharge of that function.

Matters reserved to the Board

  1. The Royal Charter provides that the Board shall not delegate the following decisions (paragraph 6.2):
  • a decision to recognise or withdraw recognition from a Regulator in accordance with the Scheme of Recognition; and
  • a decision to undertake an ad hoc review in accordance with the Scheme of Recognition. Otherwise, the Charter (paragraph 6.1) gives the Board the power to determine and regulate its own procedures.
  1. In accordance with these powers, the following matters are reserved to the Board for decision:

(1) Royal Charter

  • A decision to recognise or withdraw recognition from a Regulator in accordance with the Scheme of Recognition.
  • A decision to undertake an ad hoc review in accordance with the Scheme of Recognition.
  • A proposed amendment to the Royal Charter (which must be ratified by a resolution that has been passed unanimously by all Members of the Board).
  • The Scheme for charging fees to Regulators.
  • Approving reports relating to any success or failure of the recognition system.
  • Approving the annual report and financial statements about the activities of the PRP – including whether it has granted recognition to, or withdrawn it from a Regulator – prior to the laying of the report before Parliament and the Scottish Parliament.
  • Approving use of the Common Seal, including altering the Common Seal and replacing it with a new one.
  • Surrendering of the Royal Charter, and subsequently winding up and otherwise dealing with the affairs of the PRP in a manner which the Board considers fit.

(2) Organisational Issues

  • Approval of the PRP’s strategy and forward programme of work.
  • Approval of the PRP’s communications strategy.
  • Approval of the PRP’s Equality, Diversity and Inclusion Policy.
  • Approval of the annual budget and any material changes to it.
  • Approval of the annual accounts.
  • Decisions to commence or defend significant litigation.
  • Approval of major items of PRP policy that raise new issues of principle.
  • Approval of the publication of any PRP public consultation paper and major decisions following that consultation.
  • Approval of the PRP’s response to any significant external consultation of strategic importance to the Panel.
  • Approval of any delegation in accordance with the PRP’s governance framework and the variation or rescinding of any such delegation.

(3) Management Issues

  • Determining the remuneration strategy.
  • Approval and strategic monitoring of health and safety policies.
  • Oversight of the capability/capacity of the PRP to meet its statutory objectives.
  • General oversight of the discharge by the executive of PRP’s business.
  • Contractual and Other Obligations with Third Parties.
  • Approval of contracts in the ordinary course of business above £25,000.
  • Approval of any memorandum of understanding or formal agreements of strategic importance that the PRP may enter into with a third party.

(4) Financial Reporting and controls

  • Review performance against the PRP’s strategy, objectives and budget and ensuring any corrective action is taken.

(5) Board Membership and other appointments

  • Appointment or removal of Board members. Appointment to or removal from committees including identification of the chair and the payment of such remuneration and allowances to any person who is a member of a Board committee but who is not a Board member.

(6) Delegation of Authority

  • Approval of terms of reference of Board committees.

(7) Governance

  • The undertaking of regular reviews of the performance of the Board and Board committees.
  • Approval and review of the governance framework other than technical changes which may be signed off by the Chair.
  • Approval and review of this schedule of matters reserved for Board decision.

(8) Legal

  • Anything that is by law reserved to the Board.

Reviewed: February 2026 (AGR)

Information Security / Business Continuity

1. Introduction

Artificial Intelligence (AI) is becoming integral to many organisations’ operations, offering opportunities for automation, insights, and efficiency. However, the use of AI also brings challenges and risks that must be managed carefully.

2. Purpose and Scope

The purpose of this framework and policy is to provide guidance, principles and processes that should be considered and followed when using or implementing AI systems within or on behalf of the organisation. It is designed to ensure that AI technologies are used safely and responsibly, addressing legal, ethical, and operational considerations, while fostering awareness of the evolving risks and opportunities that AI presents.

It serves as a flexible framework that can be adapted to the specific needs of the PRP as the use of AI evolves. It applies to all AI tools, models, and platforms which may be used by the organisation, its staff and contractors, as well as the data and systems they interact with.

3. Policy Definitions

Term Definition
Artificial Intelligence (AI) A range of algorithm-based technologies and approaches that mimic human intelligence by enabling machines to learn, reason, and make decisions to solve complex tasks.
AI Systems A machine-based system that uses one or more AI technologies, data and processes to make inferences and generate outputs (such as predictions, content, recommendations or decisions) which influence environments or actions. An AI system may operate autonomously or with human oversight. This includes generative AI tools such as ChatGPT, Copilot, and similar systems.
AI Governance A framework of policies, procedures and oversight mechanisms that oversees the ethical, legal, and safe technical management of AI systems with appropriate accountability, transparency, and risk management.
AI Technologies AI methods, models, and tools used to develop and operate AI Systems, including – without limitation – supervised, unsupervised, and reinforcement learning; deep learning; predictive analytics; natural language processing; computer vision; speech or image recognition; and statistical or rule-based approaches.
Data Integrity The accuracy, completeness and consistency of data used in AI systems.
Bias Unfair or discriminatory outcomes produced by an AI System due to flawed data, design, or assumptions.
Ethics Principles of fairness, accountability, transparency, and responsibility as they relate to the use of AI.

4. Policy Statements

4.1 Transparency and Disclosure

The PRP is committed to openness and transparency about its use of AI in its work, and in the services provided by its suppliers, and to ensuring that any use of AI meets the legal, ethical, and operational standards expected of a body exercising a public function.

These include:

  • Public Law Principles – Ensuring AI-assisted decisions are lawful, reasonable, fair, and subject to appropriate human oversight.
  • Transparency – Disclosing when AI or AI Systems are used materially in delivering the PRP’s public functions or significantly influences PRP decisions, recommendations or reports.
  • Equality – Meeting the Public Sector Equality Duty under the Equality Act 2010, including assessing and mitigating risks of bias or discrimination.
  • Human Rights – Ensuring AI use respects rights to privacy, freedom of expression, and non-discrimination under the Human Rights Act 1998.
  • Data Protection – Complying with the UK GDPR and Data Protection Act 2018, including safeguards for automated decision-making.
  • Ethics – Acting in accordance with the Nolan Principles of Public Life and recognised public sector guidance.

The PRP does not currently provide, deploy or endorse the use of AI or AI Systems or Technologies in delivering the PRP’s public functions and no uses of AI meets the threshold for public reporting at this time. This Statement will be updated on the PRP’s website whenever material changes occur.

5. Artificial Intelligence (AI) Policy

This Policy sets out the principles and processes to identify and manage risks associated with the use of AI Systems and Technologies. It is intended to ensure the responsible use of AI to safeguard the PRP’s operations, reputation and compliance with legal requirements.

6. Scope

This Policy applies to all PRP staff, including board members, contractors and suppliers, when:

  • engaging with PRP third-party suppliers that use AI; or
  • using, evaluating or deploying AI or PRP-related activities.

7. Policy Principles

  • Transparency: The PRP is committed to understanding and addressing the implications of AI Systems and Technologies in its operations and those of its suppliers.
  • Awareness: AI systems, tools and technologies offer exciting possibilities but carry risks, including data security breaches, bias, intellectual property infringement, and the potential for incorrect, unfair or inappropriate outputs. Staff must be aware of these risks and take steps to mitigate them.
  • Compliance: All use of AI tools for PRP-related purposes must adhere to applicable laws, regulations, industry specific guidelines, and organisational policies including those relating to Data Protection, Freedom of Information, Equality, Human Rights, Records Retention, Information Security, and Procurement.
  • Proportionality: The PRP’s approach to AI risk management will be proportionate to its size, operational scope and duties.

8. AI Systems

The PRP does not provide or endorse the use of AI Systems or Technologies for staff or contractor use. No AI System or Technology may be installed or used on PRP systems or networks without pre-approval in writing from the Chief Executive, following a formal review, disclosure, and the assessment and mitigation of potential risks.

If staff or contractors access publicly available AI tools in relation to PRP-related activities, these Policy requirements must be strictly adhered to.

9. Data Sensitivity and Protection

Any AI System or Technology used for any purpose related to the organisation may only be used to process data that is strictly appropriate for the intended task, with proper legal grounds, permissions and security protections, such as anonymisation or encryption where necessary.

10. Prohibited Uses

10.1 Confidential Information

Staff must not use AI Systems or Technologies for tasks using or involving:

  • PRP confidential, restricted or proprietary information including but not limited to unpublished minutes or decisions;
  • PRP controlled personal data about any individual; or
  • PRP supplier or third-party confidential, personal, restricted or proprietary information including but not limited to commercial terms.

10.2 Public Functions

AI-generated outputs may contain biased, inaccurate, inappropriate or infringing data which could lead to harm if used without proper validation or attribution. Staff must not use AI Systems or Technology for any Public Function purpose without prior written approval from the Chief Executive and appropriate Oversight:

  • “Public Function” refers to any activity where AI may be used materially in delivering the PRP’s public functions or significantly influences PRP decisions, recommendations or reports.
  • “Oversight” means an appropriate level of human supervision to confirm that outputs are lawful, rational and procedurally fair, aligned with PRP’s standards, contain no factual inaccuracies or bias, pose no reputational or legal risks and meet transparency expectations.

The PRP will maintain a transparency record on its website of any instance where AI is used in materially delivering the PRP’s public functions or significantly influences PRP decisions, recommendations, or reports.

11. Internal Use

Subject to the provisions of this Policy, the PRP does not prohibit staff from accessing publicly available AI Systems to support limited PRP-related activities as follows:

  • personal efficiency and effectiveness such as undertaking routine administrative tasks, general research, summarising or analysing a public news article or creating initial drafts; or
  • educational or experimentation purposes in raising awareness of the AI landscape.

Provided that staff only input publicly available or anonymised non-sensitive data which is not subject to Prohibited Use restrictions above.

While AI tools may assist with routine and repetitive tasks, staff remain fully accountable and responsible for verifying the accuracy, appropriateness, and legality of any AI-generated outputs before incorporating them into final work product and for ensuring it aligns with the PRPs standards and this Policy.

12. Engaging Suppliers

Staff must be particularly aware of AI risks in supplier interactions. Staff must review, assess and mitigate supplier disclosures on AI for potential risks in accordance with the Supplier Checklist and, where deemed necessary, include AI-specific clauses to mitigate risks in accordance with the Procurement Policy.

Any concerns or questions about supplier AI systems must be reported without delay to the Chief Executive.

13. Incident Reporting

Staff must promptly report any AI incidents or breaches of this Policy to the Chief Executive in accordance with the Risk Management Policy, for example where:

  • PRP sensitive or confidential information may have been exposed via an AI tool;
  • issues arise with supplier AI Systems that could impact PRP operations or reputation, such as producing biased or inaccurate outputs; or
  • a data incident involves an AI System.

In the event of receiving a report the Chief Executive shall follow the Risk Management Policy and related incident management procedures to mitigate any risks, investigate the issue, and ensure that the Board is kept appropriately informed.

14. Risk Assessment

Any AI Systems being considered for deployment by the PRP or its contractors must undergo a risk assessment before being implemented or used to assess their scope and potential impact. This includes evaluating the type of data the system processes, the potential risk of bias, hallucination or discrimination, and ensuring compliance with relevant regulatory frameworks.

Framework to evaluate risks:

Framework to evaluate risks

15. Governance and Oversight

  • Policy Ownership: The Chief Executive and Board are responsible for overseeing this Policy’s implementation and addressing any AI-related issues or concerns raised by staff.
  • Accountability for Improper Use: Violations of this Policy may result in disciplinary action in accordance with PRP’s internal procedures.
  • Training: A periodic awareness session for staff and Board members will be provided to support understanding of AI-related risk as deemed appropriate.
  • Monitoring and Transparency: The PRP Audit & Risk Committee will review compliance with this Policy during its annual governance review process and may use self-assessment tools for this purpose. This will include a review of the PRPs published transparency record to update it as needed. As part of this review PRP staff must disclose if limited internal use of AI Systems is being made repeatedly for the same type of work which may indicate an evolving dependency to be addressed.
  • Policy Review: This Policy will be reviewed and updated annually to reflect changes in technology, public and regulatory expectations, the PRP’s operational needs and upon identification of any new AI-associated risks.

Updated: 20 January 2026 / WC

Definition

  1. Business Continuity Management (BCM) is about identifying those parts of our business that are critical and planning how we would maintain these if an incident occurs.

Implementation

  1. To implement business continuity, we need to identify:
  • our key products and services;
  • the critical activities and resources required to deliver these;
  • the critical risks to these activities; and
  • how we will maintain these critical activities in the event of an incident (loss of access to premises, loss of utilities, etc.).

Objectives and strategy

  1. Our Business Continuity Management Policy aims to ensure that systems and plans are designed to address significant disruptions that might affect our capabilities to perform our day-to-day activities.
  2. These are likely to include:
  • loss of staff and Board Members;
  • loss of systems;
  • loss of access to premises;
  • loss of key suppliers; and
  • disruption to transport.
  1. We will identify the critical risks that relate to the above groups and develop appropriate mitigations to address any major disruption to our services. We will follow nationally accepted best practice in this area.

Roles and responsibilities

  1. It is essential that this area of work has the full support of the Board and the Executive.
  2. The following paragraphs set out the key roles the Board and the Executive have for delivering this area of work and ensuring that it is actively managed on an ongoing basis.
  3. The Board will review this policy on an annual basis to ensure we have robust and sensible plans in place.
  4. The Chief Executive Officer is responsible for the Business Continuity of the organisation. The Chief Executive will review the Emergency and Disaster Recovery Plan and critical risks on an annual basis with the Audit and Risk Committee. As part of this review, the plan will be challenged and tested and updated as required. We will also link this review to a review of our main identified risks to ensure that all the known risks are covered by this process.
  5. Staff will be trained as required and the plans developed with the relevant parties as necessary.

Corporate standards and guidance

  1. This policy and associated plan will be stored on our shared secure system and updated annually as necessary.

Updated: April 2026 (AGR)

  1. Purpose

1.1 This document sets out our policies on the rights of individuals under Data Protection Legislation. The individual rights covered in this policy are:

  • the right to be informed;
  • the right of access (subject access requests);
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to data portability;
  • the right to object; and
  • rights in relation to automated decision making and processing.

1.2 The General Data Protection Regulation (GDPR) together with the Data Protection Act 2018 (the Data Protection Legislation) sets out the responsibilities of those dealing with personal data and the rights of individuals to access their personal data. All staff, contractors and any third party working on behalf of the Press Recognition Panel (PRP) are contractually bound to comply with the Data Protection Legislation and other relevant policies.

  1. Introduction

2.1 Data Protection Legislation gives you the right to confirmation that your data is being processed, to know what information is held about you, how that information is processed, and receive access to this data. It provides a statutory framework to ensure that personal information is handled properly.

2.2 The purpose of allowing access to personal data is so that you are aware of and can verify the lawfulness of the processing.

  1. What is personal data

3.1 Personal data means any information relating to an identified individual or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name. This includes any expression of opinion about the individual and any indication of the intentions of the Data Controller (i.e. the PRP).

3.2 This applies to both information held electronically and manually.

  1. Right to be informed

4.1 The PRP is committed to being transparent over how we use personal data.

4.2 We inform people how we use their personal data through our privacy statement (published on our website) and we may make other information available depending on the circumstances.

  1. Right of access (subject access request)

What is the PRP’s general policy on providing information?

5.1 We are committed to operating openly and responding to all requests for information. We welcome ‘informal’ requests and these may be a quicker and more effective way for you to access particular information. We will explain to you whether we are able to comply with any particular request.

5.2 If you wish to make a ‘formal’ subject access request, in accordance with the provisions of Data Protection Legislation, we will provide you with:

  • confirmation that your data is being processed;
  • access to your personal data; and
  • other supplementary information as set out in Data Protection Legislation.

How do you make a right of access (subject access request)?

5.3 A subject access request (“SAR”) must be made in writing and we will require you to provide your full name and a contact address (either a postal address or an email address) and details of the specific information you require and any relevant dates.

Confirmation of Identity

5.4 The PRP recognises that individuals may initially seek to exercise their subject access rights in a range of different ways including by telephone. However, because of the statutory requirement to be satisfied as to the applicant’s identity, the PRP will ordinarily ask any prospective applicant to provide written confirmation (via email or letter). We will not progress a SAR until we are satisfied as to the applicant’s identity. We will routinely ask for a copy of a passport, driving licence, bank statement or other proof of identity.

5.5 Where we are satisfied as to the identity of the person making the request (for instance if a request were made by a current or past employee), we may elect to waive the requirement for the applicant to provide proof of identity. The decision to waive proof of identity will be taken by the CEO.

What is the timeframe for responding to subject access requests?

5.6 We will log the date the request was received (and the applicant’s identity confirmed).

5.7 We will seek to provide you with the information as soon as possible and not later than one month of receipt. If a request is particularly complex or numerous requests have been submitted we may extend the response time by up to two further months. However, if this is necessary we will contact you within a month of your original request to advise you of this and to explain the reasons why. We will seek to provide as much information as possible as early as possible within that period and may make a ‘staged’ disclosure of information.

5.8 We will inform you without delay, and no later than one month after receiving the request, if we do not intend to take action in response to the request, including the reasons why the PRP does not intend to take action in connection with the request and the right to make a complaint with the ICO or seek a judicial remedy.

What do we do when we receive a subject access request?

Collation of information

5.9 We will undertake a reasonable and proportionate search for the personal data requested, in conjunction with other relevant staff who will be responsible for assisting the team to locate and extract any relevant personal data.

5.10 We will check that we have enough information to find the information you have requested. If we feel we need more information in order to clarify the request, then we will promptly ask you for this.

Issuing our response

5.11 Once any queries that PRP may have around the information requested have been resolved, a copy of the information will be provided to you.

5.12 Before sharing any information that relates to third parties, we will where possible anonymise information that identifies third parties unless it is reasonable to disclose that information or we have their consent. Whilst the right under Data Protection Legislation is to “personal data”, rather than documents, we will where appropriate and as a matter of discretion, try to provide you with contextual information or entire documents to help you understand your information.

5.13 We will explain any complex terms or abbreviations contained within the information when it is shared with you. Unless specified otherwise, we will also provide a copy of any information that you have seen before.

5.14 Where we hold data about a Data Subject, the PRP’s response shall contain the following information:

  • the purpose of the processing;
  • the categories of the personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  • the right to lodge a complaint with the UK supervisory authority (The Information Commissioner’s Office (ICO));
  • where the personal data is not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject; and
  • an explanation of whether and why any exemptions have been applied to the Personal Data we hold.

5.15 Any preferences of the data subject will be taken into account in determining the format in which the information is disclosed. Where the request has been made through electronic means (including email), in the first instance we will communicate our response in an electronic format, using PDF or other commonly accessible formats to provide personal data.

5.16 Appropriate security measures will be taken to protect data during the course of its disclosure, including encrypted transfer mechanisms. Where possible, the information will be disclosed in a secure, readable electronic format to minimise costs, provide an audit trail, protect the environment, and to promote the security of the information. Any personal data disclosed via hard copy will be sent via recorded delivery.

Will there be a fee?

5.17 Information will usually be provided free of charge.

Are there any grounds we can rely on for not complying with a subject access request?

Exemptions

5.18 Once all relevant information has been located, the CEO will review the data prior to disclosure and will be responsible for deciding whether any exemptions apply under Data Protection Legislation on a case-by-case basis.

Manifestly unfounded or excessive requests

5.19 If a request is manifestly unfounded or excessive, particularly if it is repetitive, the PRP can either charge a reasonable fee taking into account the administrative costs of providing the information or refuse to respond to the request.

5.20 Where we refuse to respond to the request we will explain why we have done so and advise of your right to complain to the ICO and to a judicial remedy. We will do this without undue delay and within one month.

5.21 In deciding whether multiple requests are excessive (or made at unreasonable intervals), and what action to take in consequence, the PRP will consider all the relevant factors, including the following:

  • the time that has elapsed since the previous request;
  • the volume of information involved; and
  • any reasons given by the applicant for wanting the same information again.

5.22 A record shall be kept of the PRP’s decision making and this explanation will be given to the applicant. The applicant may ask for a review of the decision.

  1. If you identify an error in our records (the right to rectification)

6.1 If we agree that the information is inaccurate or incomplete, we will rectify it and where practicable, destroy the inaccurate information. Please note that a difference in opinion or interpretation is not the same as an inaccuracy, but we may record your disagreement with the data in question.

6.2 If we have disclosed the personal data in question to a third party we will inform the third party of the rectification unless this is impossible or involves disproportionate effort. On request we will inform you of any third-party recipients.

6.3 We will respond to any request for rectification within one month although we reserve the right to extend this by two months where the request is particularly complicated.

6.4 If we do not agree the information is inaccurate or we cannot delete the information, we will make a note of the alleged error and keep this on file. We will also explain why this is the case and advise of your right to complain to the ICO and to a judicial remedy. We will do this without undue delay and within one month.

  1. If you want the PRP to stop processing your data and delete it (the right to erasure)

What is the right to erasure?

7.1 The right to erasure is also known as the ‘right to be forgotten’. This is effectively the right to request the deletion or removal of your personal data where there is no compelling reason for the PRP to process (or continue to process it).

When does it apply?

7.2 The right to erasure is not an automatic ‘right to be forgotten’ and your right to erasure only applies in certain circumstances including the following:

  • it is no longer necessary for the purposes it was originally collected;
  • where the PRP is relying on consent for processing and you withdraw this consent;
  • where you object to the processing of your personal data and there is no overriding legitimate interest to continue with the processing;
  • the personal data was not processed in line with Data Protection Legislation and is therefore unlawful; and
  • erasure is necessary to comply with another legal obligation.

Situations where the PRP may refuse to consider a request

7.3 There are certain circumstances where the PRP may refuse to comply with a request. These may include the following:

  • to exercise the right of freedom of expression and information;
  • where the information is needed to comply with a legal obligation or public interest task;
  • where the information is for public health tasks in the public interest;
  • where the information is for archiving for public interest or research purposes; and
  • where the information is held for defending legal claims.

How to apply

7.4 Should you wish to make such a request you should send us the request in writing. When we receive the request, we will send you written notice that either we have complied with your request, intend to comply with it or state the extent to which we will comply with it and why as soon as possible.

7.5 If we have disclosed the personal data in question to a third party we will inform the third party of the erasure unless this is impossible or involves disproportionate effort. On request we will inform you of any third party recipients.

  1. If you want the PRP to restrict the processing of your data (the right to restrict processing)

When does it apply?

8.1 You also have a right to ask us to block or restrict processing of your personal data in some circumstances:

  • where you contest the accuracy of the personal data, we will restrict processing of this data until we can verify the accuracy;
  • where you object to the processing and we require time to consider whether the legitimate grounds for processing overrule this objection;
  • where the processing is unlawful but you oppose erasure and request restriction instead; and
  • where we no longer require the personal data but you require it for another purpose such as to defend a legal claim.

What we will do

8.2 Where we restrict the processing of your data we will continue to store it but will not process it further.

8.3 We will hold a log with the minimum amount of information necessary to ensure that we continue to be able to restrict the processing in future for example where we are required to back up the system we may need to check our records to ensure no information is inadvertently added back onto our stakeholder list.

8.4 If we have disclosed the personal data in question to a third party we will inform the third party of the restriction unless this is impossible or involves disproportionate effort. On request we will inform you of any third party recipients.

8.5 If we decide to lift the restriction for any reason we will inform you in writing.

  1. The right to data portability

What is the right to data portability?

9.1 The right of data portability is the right to request your information to reuse for your own purposes in a different environment. It effectively allows you to transfer your personal data from the PRP’s IT environment to that of another organisation, securely and without hindering its usability.

9.2 In relation to the PRP’s work it will be extremely rare for the right of data portability to apply.

When does it apply?

9.3 The right to data portability applies where:

  • you have provided the information to us;
  • the processing is based on your consent (or for the performance of a contract); and
  • the process is carried out by automated means.

What we will do

9.4 Where you meet the requirements we will provide your data free of charge.

9.5 We will provide the information within one month of your request except where your request is particularly complex or numerous requests have been submitted. In this case, exceptionally, we may extend this period by up to a further two months.

9.6 Where we are not taking any action in relation to your request, we will write to you within a month to explain why and to inform you of your right to complain about the PRP’s decision.

9.7 Where the data includes personal data relating to another party we will consider whether providing this data breaches their rights.

  1. How to object to the PRP’s processing of your personal data (the right to object)

What is the right to object?

10.1 You have the right to object to any processing based on legitimate interests, the performance of a task in the public interest or exercise of official authority or processing done for the purposes of research, or direct marketing.

10.2 See our Privacy statement or contact us for more information on the basis for processing.

Objecting on the grounds of legal tasks or the PRP’s legitimate interests

10.3 Your objection must be on ‘the grounds of your particular situation’ – please specify what this is when you make the request in order to help us to respond to your request.

10.4 We will stop processing the personal data unless:

  • we have legitimate grounds for the processing, which override the interests, rights and freedoms set out in your request; or
  • the processing is for the establishment, exercise or defence of legal claims.

Objecting on the grounds of direct marketing (PRP updates, etc.)

10.5 We will stop processing your personal data on the grounds of direct marketing as soon as you request this.

What we will do

10.6 We will respond to your request within one month except where your request is particularly complex or numerous requests have been submitted. In this case we may extend this by up to two further months. However, if this is necessary, we will first check that we have enough information to be sure of your identity. Where we are satisfied as to the identity of the person making the request, we may elect to waive the requirement for the applicant to provide proof of identity. However, if we are not satisfied as to the identity of the requester we will take reasonable steps to identify the requester. We will contact you within a month of your original request to advise you of this and to explain the reasons why.

10.7 Where we are not taking any action in relation to your request we will write to you within a month to explain why and inform you of your right to complain.

10.8 Where the data includes personal data relating to another party we will consider whether stopping processing providing this data breaches their rights.

  1. Rights related to automated decision making

11.1 The PRP does not engage in “automated decision making”, which means that no decisions are made about you solely by automatic means without any human involvement at all.

  1. Checking of identity when we receive an individual rights request from a person acting on behalf of a data subject

12.1 Where we receive an individual rights request by a person acting on behalf of the data subject, the PRP will take reasonable steps to verify the identity of the data subject concerned, the person making the request on behalf of the data subject and that that person has the appropriate authority to make the request and receive our response to the individual rights request.

  1. Audit and record keeping

13.1 The PRP will maintain records of:

  • the requests it receives;
  • the ‘raw’ products of any searches undertaken;
  • a master audit/redacted copy of the information proposed for disclosure;
  • any correspondence with/the final response given to the applicant; and
  • any advice or other records received or prepared in the course of handling the request.
  1. Our complaints procedure

14.1 If you are not satisfied with the way we have dealt with your individual rights request or any other action in relation to this policy you can seek recourse through our internal complaints procedure, the Information Commissioner or the courts.

14.2 The Chief Executive will deal with any written complaint about the way a request has been handled and about what information has been disclosed. The Chief Executive can be contacted at:

Susie Uppal Chief Executive Press Recognition Panel 4 Winsley Street London W1W 8HF

Email: suppal@pressrecognitionpanel.org.uk

14.3 If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Telephone: 0303 123 1113 Email: casework@ico.org.uk

Updated: April 2026 (AGR)

Introduction

  1. Effectively managing the information we hold and dispose of is critical to any business’ organisational success. We have to be able to access information in a simple and effective manner and to be able to dispose of information that is no longer relevant to our business needs.
  2. Legal requirements determine that some of the information we hold such as financial records, contracts and HR records must be stored for predetermined time periods. The length of time we hold other records is determined by us and should be determined on what information we need to keep in order to operate effectively.
  3. This Policy sets out our current position on what to keep and how long it should be kept for. It sets out what electronic information should be kept for business, legislative and historical reasons and what information should be routinely deleted.
  4. Once you have identified a record (see definition of a record below) you need to determine how long you need to keep it and why. All records should be stored on our Egnyte Shared Account and not on local hard drives. This is to ensure there is access for all staff to the records required and that records are secure.
  5. The key to ensuring documents can be found easily is to ensure that staff use the file plan structure currently in place. If you need to change this structure you will need to speak to the Executive Administration Manager.

Retention Schedule

  1. The Retention Schedule set out in Appendix A sets out the minimum length of time that we should retain records. It is designed to ensure we can:
  • find and use the information we need;
  • justify our decisions and provide a clear audit trail;
  • maintain our corporate memory;
  • comply with legislative and regulatory requirements;
  • ensure that the disposal of information has been carried out according to the agreed policy;
  • mitigate the cost and potential liabilities associated with retaining information that is not required;
  • ensure storage costs and administrative overheads are justified by business needs; and
  • improve the security of our information.
  1. Appendix A identifies the functional area, where the record should be saved and for the minimum period the record should be stored. This is referenced where appropriate to the citation for the required retention period.

Destruction/Disposal

  1. Paper records containing confidential and/or personal information should be shredded securely using the facilities provided. Electronic versions of documents may only be downloaded onto non-PRP devices, if adequate security measures are in place, and they must be deleted as soon as possible.

Further Information

  1. If you are unsure about any aspect of this policy, please contact the Executive Administration Manager for further advice.

Appendix A

What is a record?

How to identify a record Is it a record?
Does the content of the item contribute to a policy decision or decision-making process? Yes
Does the content of the item contribute to an action taken or a decision made? Yes
Does the content of the item contribute to a change in our policy or procedure? Yes
Does the content have financial or legal implications? Yes
Does the content need to be approved by or reported to another individual or an external body? Yes
Does it have to be created as a result of specific legislation? Yes

If none of the above criteria apply, it is not a record and can be destroyed when it is no longer required.

Governance processes

What to keep Where to save it When should it be saved When should it be deleted Who should action this
Early policy drafts not shared with colleagues Personal drive Immediately When superseded Originator
Drafts shared with colleagues for comment Shared drive When access is required When superseded Originator
Drafts that have been to Board for discussion Shared drive When approved for discussion with the Board When superseded Executive Administration Manager
Final policy documents Shared drive When approved by the Board When superseded Executive Administration Manager
Team meeting project plans and notes Shared drive Once approved Review annually Executive Administration Manager
Board papers, agendas and minutes Shared drive and website Once approved Permanent Executive Administration Manager
Financial information relating to business operation Shared drive Immediately 6 years from last action Executive Administration Manager
Contractual information (those tendered) Shared drive Immediately 6 years from termination of the contract Executive Administration Manager
Annual plans and reports Shared drive Once approved Permanent Executive Administration Manager
Employers’ liability insurance Shared drive Immediately Expiry of policy + 40 years Executive Administration Manager
Other insurance policies Shared drive Immediately Expiry of policy + 6 years Executive Administration Manager
Claims made under insurance policies Shared drive Immediately Permanent Executive Administration Manager
Legal claims Shared drive Immediately Settlement of the case + 6 years CEO
Legal advice regarding operational issues Shared drive Immediately Permanent CEO

Application and review processes

What to keep Where to save it When should it be saved When should it be deleted Who should action this
All relevant documents relating to applications, reviews, and any required actions, and all relevant correspondence Shared drive Immediately Permanent CEO

Information requests

What to keep Where to save it When should it be saved When should it be deleted Who should action this
Information requests or complaints received, and our response to these Shared drive Immediately Review annually Executive Administration Manager

Human Resources Information

What to keep Where to save it When should it be saved When should it be deleted Who should action this
Leaver and joiner forms, annual leave, special leave, medical and sickness records, termination of employment by resignation, redundancy, retirement or dismissal Shared drive Immediately Termination of employment + 6 years CEO
Performance management, probation and disciplinary, training and development Shared drive Immediately Termination of employment + 6 years CEO
Reportable accidents, injuries or deaths in connection with work Shared drive Immediately Incident + 3 years CEO
Grievances Shared drive Immediately Conclusion of investigation + 6 years CEO

Stakeholders

What to keep Where to save it When should it be saved When should it be deleted Who should action this
Contacts database Shared drive Immediately Review annually; delete immediately if requested to do so by an individual CEO
Consultation responses Shared drive Immediately Permanent CEO
Correspondence and notes on discussions with interested parties Shared drive Immediately Review annually CEO
Diversity monitoring forms Shared drive Immediately Review annually; delete immediately if requested to do so by an individual Executive Administration Manager
Statements to the media and press releases Shared drive Immediately Permanent CEO

Reviewed: April 2026 (AGR)

Background

  1. The PRP is not listed within the schedule to the Freedom of Information Act 2000 (‘the Act’) and so is not a body to which its provisions apply. The Board nevertheless operates as if the provisions of the Act apply to it, including producing and operating a publication scheme and considering and responding to information requests.
  2. The PRP’s publication scheme sets out the information that we will routinely make available to the public, and where and when that information will be available.
  3. If the information you seek is not available under our publication scheme, then you can make a request for the information in accordance with the Act. This provides that, subject to certain defined exceptions, any person making a request for information from us is entitled:
  • to be informed in writing whether or not we hold information of the description specified in the request; and
  • if we do, to have that information communicated to them.
  1. Our intention is to publish a disclosure log containing details of responses to information requests received by the PRP where that information is not routinely published or covered in the publication scheme.
  2. If your request relates to personal information about you, please refer to the PRP’s Data Protection policy.

Making a request for information

  1. If you want to make a request for information from the PRP, then you should write to us providing:
  • your name;
  • your return address; and
  • a detailed description of the information that you are requesting.
  1. You can submit your request to the PRP’s Executive Administration Manager at: wcollinson@pressrecognitionpanel.org.uk or:

Wendy Collinson
Executive Administration Manager
Press Recognition Panel
Mappin House
4 Winsley Street
London W1W 8HF

Please direct any request for assistance in completing your request for information to wcollinson@pressrecognitionpanel.org.uk.

Processing a request

  1. Upon receipt of a request, the PRP will:
  • check the request is valid – if further clarification is needed to assist in identifying the exact information required, this will be dealt with immediately upon request;
  • enter the request on the PRP’s FOI request log;
  • send an acknowledgement letter to the applicant; and
  • generally respond to the request within 20 days (there may be circumstances when we need longer to respond – details are set out below).

Timescales

  1. We will aim to respond to your request for information promptly, and generally within 20 working days from the day after the date on which your request was received.
  2. Extra time may be taken to respond to a request for information where, for example:
  • a fee is deemed payable, in which case the response period will be put on hold until the fee is received;
  • the request for information is being considered under a disclosure exemption akin to the Act’s public interest test, in which case the response period may be extended by a reasonable period. We will tell you within the response period which exemption we believe applies and we will give you an estimate of the date by which we expect to reach a decision regarding the application of this exemption.

Refusing a request

  1. A requester may ask for any information that is held by the PRP. However, in some cases, there will be a good reason why we will not make public some or all of the information requested. We would normally refuse a request under the following circumstances:
  • it would cost too much or take too much staff time to deal with the request;
  • the request is vexatious;
  • the request repeats a previous request from the same person; and
  • the request relates to personal data and releasing it would be contrary to the Data Protection Act 2018.
  1. While the PRP is not subject to the Act, we have chosen to apply the framework of exemptions set out in the Act to all information requests. The PRP will not classify information as exempt from disclosure unless there are very clear arguments for doing so. Some exemptions relate to particular types of information, for instance, information relating to the development of policy. Other exemptions are based on the harm that would arise or would be likely arise from disclosure, for example, if disclosure would be likely to prejudice a criminal investigation or prejudice someone’s commercial interests.
  2. Below is a list of exemptions that are most likely to be relevant to the information the PRP holds:
  • Information accessible by other means (FOI Act section 21 exemption);
  • Personal information (FOI Act section 40 exemption);
  • Information provided in confidence (FOI Act section 41 exemption);
  • Information intended for future publication (FOI Act section 22 exemption);
  • Investigations and proceedings conducted by a public authority (FOI Act section 30 exemption);
  • Prejudice to the effective conduct of public affairs (FOI Act section 36 exemption);
  • Legal professional privilege (FOI Act section 42 exemption); and
  • Commercial interests (FOI Act section 43 exemption).
  1. Exemptions 1 to 3 above are absolute, and we will not apply a test akin to the Act ‘public interest test’. However, the majority of the Act exemptions require public bodies to conduct a ‘public interest test’ meaning that the public interest arguments will be considered before deciding whether or not to disclose information. The PRP will adopt a similar approach in assessing requests for information, which might mean the PRP disclosing information in spite of an exemption, where it is in the public interest to do so.
  2. Where the PRP refuses all or any part of a request, we will send the requester a written refusal notice. We will issue a refusal notice if we are either refusing to say whether or not the information is held at all or confirming that information is held but refusing to release it.

Consultation with third parties and transferring requests

  1. We may need to consult third parties in order to reach a decision about whether or not the requested information can be released.
  2. If you wish to be notified before we consult a third party about your request for information, you should state this in your application.
  3. If you have made a request for information that we believe is held by another public authority, it may be appropriate for you to submit a new request directly to that public authority. Alternatively, we may transfer your request to that public authority. Where we decide that it is appropriate to transfer your request to another public authority, we will first check that it holds the information that you have requested.
  4. If you wish to be notified before we transfer your request for information to another public authority, you should state this in your application.

Fees

  1. Although the PRP is a wholly independent body, its funding is via Exchequer grant and fees. We will charge a fee for complying with a request for information in accordance with the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004.
  2. If the cost of locating, retrieving and extracting the information is £450 or less, we may charge only for disbursements including photocopying, printing and postage costs, if at all. If the cost is more than £450, we are may choose not to comply with your request. However, we will consider whether it is possible to provide any information within the cost ceiling of £450. We will also consider whether it is reasonable to answer your request and charge an appropriate fee.
  3. You will be notified in advance about any fee that you must pay to the PRP.

Complaints procedure

  1. If you are dissatisfied with the response to your request for information (including any decision to charge a fee), you are invited to discuss the response directly with the Executive Administration Manager, Catherine Stone using the contact details above.
  2. However, if this informal discussion does not resolve your complaint, then you should submit your complaint in writing to the PRP’s Chief Executive Officer: suppal@pressrecognitionpanel.org.uk or:

Susie Uppal
Chief Executive Officer
Press Recognition Panel
Mappin House
4 Winsley Street
London W1W 8HF

  1. The Chief Executive Officer will consider your complaint, and will confirm, reverse or amend the decision. You will be advised in writing of the outcome of your complaint.
  2. If you are dissatisfied with the Chief Executive Officer’s decision, then you should direct your complaint to the Chair of the Board:

Chair
Press Recognition Panel
Mappin House
4 Winsley Street
London W1W 8HF

  1. As the PRP is not subject to the Act, there is no right of complaint to the Information Commissioner.

Further information

  1. The Information Commissioner is responsible for promoting good practice and ensuring compliance with the Act. While the Information Commissioner does not have jurisdiction in relation to the PRP because we are not a body to which the FOI provisions apply, the Information Commissioner’s Office is nevertheless the leading source of guidance about the Act:

The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
T: 0303 1231113
W: https://ico.org.uk

Review: February 2026 (AGR)

  1. The Executive are located in co-shared serviced offices which are open Monday to Friday 8.30-6.00. The cleaning is undertaken by the service provider on a daily basis as part of our contractual agreement.
  2. We genuinely care about the health and safety of our Board Members and staff and this is reflected in this health and safety policy.
  3. The statement of general policy and arrangements at Annex A is based on a sample policy statement and other guidance available on the HSE website at hse.gov.uk/risk. This has helped us to think about the things that should be documented and built into our own Health and Safety policy, and includes elements such as remote working, staff consultation and training etc. Susie Uppal, Chief Executive Officer, has been designated as the most competent (experienced and capable) person to take responsibility for health and safety issues. She is supported in her role by Wendy Collinson, Executive Administration Manager. Their respective roles are identified on the following pages.
  4. Following the move of the Executive to homeworking and co-sharing services offices, it has been assessed that the home working is low risk due to the purely office type nature of the work. No further risk assessment is deemed necessary at this stage and the CEO will continue to monitor the situation.
  5. The Health and Safety policy is signed off by the Board and we will review regularly and update the document.
  6. Accidents and ill health at work will be reported under RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations) hse.gov.uk/riddor.

Annex A

This is the statement of general policy and arrangements for the Press Recognition Panel
Susie Uppal – Chief Executive Officer has overall and final responsibility for health and safety
Statement of general policy Responsibility of: Name/Title Action/Arrangements
Prevent accidents and cases of work-related ill health by managing the health and safety risks in the workplace Susie Uppal Chief Executive Officer Relevant risk assessments completed and actions arising out of those assessments implemented. (Risk assessments reviewed when working habits or conditions change.)
Provide clear instructions and information, and adequate training, to ensure employees are competent to do their work Susie Uppal Chief Executive Officer We will ensure that suitable arrangements are in place to cover employees engaged in work remote from the main office.
Implement emergency procedures – evacuation in case of fire or other significant incident. Spaces Susie Uppal Chief Executive Officer Spaces are responsible for:
  1. Ensuring escape routes well signed and kept clear at all times.
  2. Evacuation plans are tested from time to time and updated as necessary.
Susie is responsible for ensuring staff are aware of the evacuation procedures in place and accounting for staff present in our office on the day of an incident.
Maintain safe and healthy working conditions, provide and maintain equipment and machinery, and ensure safe storage. Spaces provide:
  • toilets, washing facilities and drinking water;
  • canteen services; and
  • kitchen facilities including hot water, microwave and fridge.
Spaces have systems in place for routine inspections and testing of equipment and machinery and for ensuring that action is promptly taken to address any defects.
Signed: (Employer) Date:
Health and safety law poster is displayed at: Communal area
First-aid box is located: Communal area
Accident book is located: Communal area

Review: February 2026 (AGR)

Introduction

  1. This policy applies to everyone (including Board Members, Independent members, staff and contractors) using the Press Recognition Panel’s (“PRP’s”) Information Technology (IT) equipment and systems and describes the rules and conduct that the PRP requires you to observe. By IT equipment and systems, we mean any device (including landline telephones, computers, tablets, mobile/smart phones or other devices whether it is a PRP-owned device or your own device) connected to the PRP’s network (including the use of emails and the internet) and any other equipment or system owned or operated by the PRP that may be used to communicate, store or process information electronically (such as the PRP’s website and social media accounts); also all emails and electronic documents sent using a pressrecognitionpanel.org.uk email address or any sent in the course of activities for the PRP using any other email address.
  2. The purpose of this policy is to protect the confidentiality, integrity and availability of PRP information to enable the PRP’s Board, employees and representatives to discharge their roles effectively. The aim of this policy is not to prevent, discourage or monitor reasonable usage of IT systems, but rather to set out clearly a code based on mutual trust and an underlying assumption that everyone will use the IT systems fairly and reasonably. Note: monitoring of usage, whether such usage occurred prior to the introduction of this policy or after its introduction, will not be carried out in the normal course of events: see Annex 1.
  3. The intention is not to impose restrictions that are contrary to the PRP’s established culture of openness, trust and integrity. The PRP is committed to protecting its Board Members, employees, consultants and itself from illegal or damaging actions by individuals, either knowingly or unknowingly, and this policy is constructed as part of that commitment.
  4. This document outlines the PRP’s security policy in relation to the use of IT equipment and systems. The policy has been created after reviewing best practice use and the relevant legislation currently in force and it is designed to ensure that we meet all legal requirements, minimise our exposure to risk, protect our information and utilise equipment and systems in the most effective manner. Inappropriate use exposes the PRP to risks including virus attacks, compromise of network systems and services and a range of legal issues.
  5. It is vital that everyone at the PRP applies this security policy in full. While the policy does not form part of anyone’s contract of employment, all users of IT systems are responsible for ensuring that they are complying with the policy and with any current legislation. Failure to comply with this policy and other guidelines could result in disciplinary action that may lead to dismissal (including termination without notice in cases of serious breaches) and the possibility of prosecution under existing legislation.

Operating principles

  1. All use of PRP IT must conform with the relevant legislation in force at the time governing the use and monitoring of e-mails and the internet (including PRP social media accounts or personal social media accounts while representing the PRP) while accessing PRP information and/or using PRP systems and devices, which principally involves: the Human Rights Act 1998, the Data Protection Act 2018, the Regulation of Investigatory Powers Act 2000 and the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (S.I. 2000, No. 2699).
  2. The PRP has also decided that, whether or not the Freedom of Information Act is extended to cover the PRP’s activities, the PRP will behave as if the Act applied to it (including therefore in relation to communications sent using IT systems). All reasonable steps will be taken to inform users about their legal rights under the legislation at the time through the communication of this policy.
  3. Other legislation taken into account in this policy includes the Copyright, Design and Patents Act 1988 and Data Protection Act 2018.

Your use of the PRP’s IT

  1. The principal purpose of the IT systems is to facilitate the legitimate business purposes of the PRP. However, it is acknowledged that everyone is entitled to means of personal communications during the working day, particularly, but not only, where there is a need to communicate urgently. Personal use of the PRP’s IT equipment, as described later in this policy, is allowed, so long as carried out reasonably and appropriately.
  2. Under no circumstances should the IT systems be used to send, receive, browse, download or store material that may be illegal, offensive or cause embarrassment to others. This includes (without limitation) the use of the PRP’s IT systems to send, receive, obtain access to, download or store pornographic material and material that is religiously, racially or sexually offensive.
  3. In particular, you may not use the PRP’s IT systems to send, or solicit, communication where the content (or any attachment) is pornographic, sexist, racist, homophobic or in any other way unlawfully discriminatory.
  4. It is important to ensure that you and the PRP are protected against the misuse of others’ copyright material and that the integrity and effectiveness of the IT systems is maintained. Accordingly, you may not install or update any software not provided or approved by the PRP without the prior permission of the Chief Executive Officer. This does not apply to updates of approved software already installed.
  5. You are responsible for the security of any IT systems or equipment assigned to you (including any unique password), and you must not allow them to be used by any other person (other than our IT consultants when providing support)
  6. Passwords should be sufficiently memorable so that you can avoid writing them down, but not obvious or easily guessed. The password should be at least 9 characters long and contain three of the four types of keyboard character (upper case, lower case, numbers and symbols in a memorable passphrase only significant to you — by way of example only — W@1LTinSh1rt . You should avoid personal information or common phrases. Different passwords should be used for different devices.
  7. To ensure compliance with this policy, use of IT systems by staff may be monitored. Such monitoring will not be carried out in the normal course of events and when monitoring does occur it will be in accordance with the practice set out in Annex 1. You should also be aware that others may have access to systems you use, the data stored or may oversee what you are doing.
  8. Staff accept that by using the PRP’s IT systems to send or receive e-mails, or to access the internet, that monitoring may take place in accordance with the practice set out in Annex 1. Any email containing confidential information should be labelled in the subject line.
  9. In exercising its right to monitor e-mails and internet usage, the PRP will comply with its obligations under the Data Protection Act 2018 and the Regulatory of Investigatory Powers Act 2000. The PRP will also comply with the Information Commissioner’s Employment Practices Code in this regard.

Personal use of the PRP’s IT Systems

  1. Use of the PRP’s IT systems by you to send and receive personal e-mail, to use the internet (including instant messaging services) or to make or receive personal telephone calls is acceptable provided that your usage:
  • is kept to a minimum;
  • does not interfere with your work;
  • does not incur anything more than trivial costs to the PRP; and
  • complies with all other PRP policies.
  1. All communications on PRP social media accounts must be approved by the Chief Executive before posting. If using personal social media accounts, such as X, Bluesky, LinkedIn or Facebook, it should be clearly stated that any views expressed are those of the individual, rather than of the PRP. Comments in respect of PRP related matters should be referred to the CEO and / or the Chair prior to posting (except when reposting an already approved message from a PRP social media account).
  2. This policy on personal use is dependent upon it not being abused or overused and the right to use PRP systems or equipment for personal use may be withdrawn or amended at any time and without notice.

PRP computers

  1. All PRP laptops and PCs should use screen savers and wallpaper appropriate to a business environment.
  2. Every individual should ensure that the computer on which they have been working that day is switched off at the end of the working day except when it is necessary for the computer to be left switched on in order to allow remote access/working.
  3. Games should not be played on any computers owned by the PRP.

When using the Internet

  1. You must not use the internet for gambling.
  2. You must not access or attempt to access any internet site or service, or any material on a site, which you know or suspect to be pornographic, illegal or likely (if disseminated) to be offensive to others. If you accidentally access any such site or material you must not save any material from it and must delete any accidentally saved, and must exit the site immediately. All such incidents must be logged and reported to the Chief Executive Officer.
  3. Personal use of the internet, for example for booking holidays or shopping, should be kept to a minimum and should not, where possible, be in public area.
  4. Be aware that web sites often keep a record of who has visited them, what was requested and from where, downloading small text files called ‘cookies’ so that they can track your behaviour on their website.
  5. Be aware that your web browser, by design, keeps its own records and copies of what sites you have visited and when.
  6. You may only download files from the Internet where there is a genuine business need to do so. To avoid importing viruses you must run a virus check on all downloaded files prior to opening them.
  7. You should be aware that the PRP could be bound by contracts that are entered into via the Internet. You must not, unless authorised, subscribe to any service via the Internet or commit the Panel to purchase any product or service.
  8. In order to preserve the rights of the PRP to material and information which are its confidential property, no information should be publicised over the Internet or made available without the prior consent of the Chief Executive Officer.
  9. Do:
  • Only visit Internet sites that have a relevance to your business interests.
  • Ensure that password and access restrictions are in place (do not allow either the browser or the site itself to retain the access password).
  • Routinely delete all cookies and remove any files from your downloads folder which are no longer required
  1. Don’t:
  • Leave the connection open longer than necessary.
  • Download software or files of any type as they can contain instructions to damage the software on your PC.

When using email

  1. Assume that e-mail messages may be read by others and so do not include in your e-mails anything which would offend or embarrass any such reader, or would embarrass the PRP if it found its way to the public domain.
  2. You must not use the PRP‘s facilities to send, or solicit, any e-mail or other message where the content (or any attachment) is pornographic, sexist, racist, homophobic or in any other way discriminatory, harassing or defamatory or which in any way breaches the PRP’s Equality, Diversity and Inclusion Policy. You must immediately delete any e-mail or attachment you receive or access through the Panel’s facilities that could be inappropriate.
  3. If a recipient asks you to stop sending them personal messages then always immediately stop.
  4. Never send messages from another person’s e-mail account or under a name other than your own without the relevant account user’s express permission or, where appropriate.
  5. Never forward confidential messages by e-mail without specific authority from the original sender.
  6. Never open an e-mail attachment from an unexpected or untrustworthy source.
  7. Remember that e-mail messages are documents and so may be disclosed in legal proceedings if relevant to the issues.
  8. Never send or forward private e-mails at work which you would not want a third party to read.
  9. Do not create e-mail congestion by sending trivial messages or unnecessarily copying e-mails to those who do not have a real need to have them.
  10. Do not advertise or forward “chain-mail” e-mails.
  11. Always remember that text, music and other content on the Internet are copyright works. Never download or e-mail such content to others unless you are certain that the owner of such works allows this.
  12. If sending important information by e-mail, always obtain confirmation of receipt (either a reply to your e-mail or by following up with a telephone call).
  13. Never agree to terms or enter into contractual commitments or make representations by e-mail without having obtained proper authority.
  14. When you type your name at the end of an e-mail, this act is just as much a signature as if you had signed it personally.
  15. Never send strictly confidential messages via the Internet, or by other means of external communication which are known not to be secure.
  16. If requested to forward such information over the Internet, make sure that the recipient knows that it is not totally secure and is willing to accept that risk.
  17. Take care not to be taken in by emails falsely appearing to come from someone else associated with the PRP (particularly where the emails appear to instruct you to, for example, pay money). If in any doubt report suspicious emails to the Chief Executive and Executive Administration Manager who will take the necessary steps with the PRPs IT service provider to check that no data breach has occurred. Do not click on any links, they may contain viruses that can infect your computer and do not share personal information like passwords or account numbers unless you initiated the contact — if you do, change your password immediately.
  18. All email communication concerning PRP business must be done using the pressrecognitionpanel.org.uk email address, the only exception to this is email communications regarding administrative matters such as the scheduling of meetings.

Physical security of electronic devices

  1. Everyone should also take appropriate steps to ensure the physical security of desktop computers, laptops, smartphones, tablets and USB sticks and other removable storage devices that contain confidential material. In particular you should not: leave devices in a car overnight; or leave devices unattended in a public place (although there is no objection to leaving them in a locked court-room during adjournments). Where possible, computers should not be placed so that their screens can be overlooked, especially in public places.

Laptops and other portable devices

  1. Particular risks to confidentiality arise from the loss of confidential material held on laptop computers, smartphones, PDAs, USB sticks and other removable storage devices. A single portable device may contain very large amounts of confidential information. The loss of information may cause considerable embarrassment to third parties as well as being a breach of the Data Protection Act. Everyone should take as much care with this material as they would with their own valuables to prevent theft or loss. Wherever possible, PRP information should be stored within the PRP’s secure SharePoint site and email traffic undertaken through PRP-registered email accounts. Downloading PRP information to non-PRP devices should be avoided. Should a laptop or other portable device storing PRP information become lost or stolen, you should notify the Chief Executive Officer immediately so that your login password can be changed and, if possible, the data on your remote devices can be wiped.
  2. No PRP devices should be taken out of the country without the specific permission of the Chair or the Chief Executive. If a PRP laptop is required to be taken to a country which is on the government’s banned list, a full risk assessment must be carried out.

Electronic security and encryption

  1. The PRP maintains a secure SharePoint environment. Records relating to the PRP’s work should only be stored in the PRP secure SharePoint environment. Download to portable media should be avoided. You must set access controls for folders for which you are responsible on a ‘zero trust’ basis — other members of staff or the Board must only be granted access to folders where they have a legitimate business need to access the information. Where the use of downloadable media is unavoidable, these must be encrypted.

Communication

  1. E-mail is a potentially insecure method of communication. Appropriate steps, such as encryption during transmission, should be taken if it is considered necessary to send particularly sensitive information by e-mail. You should never send the password required to decrypt an attachment in the same e-mail as the attachment since this would self-evidently defeat the purpose of encryption to avoid interception. If you arrange for e-mails to be sent to your mobile telephone, smartphone or PDA, you should ensure that the device is suitably password-protected with a nine character password. Connecting to the internet via a (non PRP) wireless network presents a particular risk of interception of communication. Particular care should be taken when connecting via public and unencrypted access points. If you use a wireless network system in your home you should ensure that it is reasonably secure for example via a Virtual Private Network (VPN).

Phone calls

  1. Reasonable usage of the PRP telephone system for personal purposes is permitted.
  2. Such usage is based on mutual trust and an underlying assumption that everyone will use telephone system fairly and reasonably.
  3. Personal telephone calls should only be made when necessary and should be kept to the minimum time required.
  4. It is recommended that personal telephone calls should not be taken in any open or communal area.

Failure to comply with this policy

  1. Breach of any of the conditions will be regarded as a disciplinary offence and serious breaches may constitute Gross Misconduct. If you fail to comply with rules and conduct in your use of the PRP’s IT systems disciplinary action will be taken that may lead to your dismissal and, if appropriate, civil and/or criminal proceedings.

Annex 1

Regulation of Investigatory Powers Act 2000

  1. This Act covers the extent to which organisations can monitor or record communications at the point at which they enter or are being sent within the employer’s telecommunications system, and applies to public and private communication networks. It gives the sender or recipient of a communication the right of action for damages against the employer for the unlawful interception of communications.
  2. There are two areas where monitoring is not unlawful. These are:
  • where the employer reasonably believes that the sender and intended recipient have consented to the interception
  • without consent, the employer may monitor in the following circumstances, as set out in the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000. These include: – to ensure compliance with regulatory practices e.g. Financial Services Authority requirements – to ensure standards of service are maintained, e.g. in call centres – to prevent or detect crime – to protect the communications system:¬ this includes unauthorised use and potential viruses – to determine the relevance of the communication to the employer’s business ¬ i.e. picking up relevant messages when someone is away from work.
  1. The PRP will only monitor or record communications in accordance with these provisions. Moreover, the PRP will make all reasonable efforts to ensure that system users know that communications may be intercepted, and any such monitoring will also comply with the provisions of the Data Protection Act 2018 (see below), and in particular the Data Protection principles on fair processing.

Data Protection Act 2018

  1. The Information Commissioner – responsible for enforcement of the Data Protection Act – published a code of practice to help employers comply with the provisions of the Data Protection Act 1998. The Employment Practices Code clarifies the Act in relation to processing of individual data, and the basis for monitoring and retention of email communications. Part 111 of the Code covers monitoring at work. All are available from the Commissioner at www.dataprotection.gov.uk The code of practice Monitoring at work: an employer’s guide states that any monitoring of emails should only be undertaken where:
  • the advantage to the business outweighs the intrusion into the workers’ affairs
  • employers carry out an impact assessment of the risk they are trying to avert
  • workers are told they are being monitored
  • the information discovered is kept secure
  • employers are careful when monitoring personal communications such as emails which are clearly personal
  • employers only undertake covert monitoring in the rarest circumstances where it is used for the prevention or detection of crime.
  1. The PRP will comply with these principles, and the updated guidance when issued by the Commissioner, in deciding when monitoring may be required and in carrying out any such monitoring activity.
Updated: February 2026 (AGR)
  1. The Press Recognition Panel (PRP) is a data controller and is committed to protecting your personal data and working in accordance with all relevant data protection legislation.
  2. This statement explains how the PRP processes and uses the personal data we collect and store.

What data do we hold?

  1. The data that we hold about stakeholders is that which you provided in your initial contact with the PRP or that we have added as a result of your interest in our work.
  2. Our records may include:
  • contact details – for example your address, email address and telephone number (we update these whenever you tell us they have changed);
  • your preferences – to help us engage you in the ways most relevant to you; and
  • information that you provide to us including in relation to email notifications, your requests to join our database and responses to consultations.
  1. We may also augment data you provide with data that is publicly available, for example we may record:
  • your interests in press regulation and the work of the PRP;
  • we are required to ensure that data we hold about you is as accurate as possible and therefore, we may update your details based on reliable publicly available sources. For example, we may update your address or business details; and
  • we use a wide variety of sources either directly or via internet search engines, some on a subscription basis to augment, update and validate the data we hold. These include:
    • Parliamentary and personal websites;
    • reliable news and press reports; and
    • Companies House and other business-related websites.
  1. The PRP will retain your data in line with our Retention and Disposal Policy and you can also exercise your rights under data protection legislation as per our Data Protection Individual Rights Request Policy.

How do we use your data?

  1. The PRP primarily uses your data to communicate PRP-related information. This can include:
  • informing you of calls for information;
  • sending you annual reports; and
  • sending you relevant updates.
  1. Communications may be sent to you by post and/or email depending on the communication preferences you have shared with us.

How will we share your data?

  1. Data is only shared with persons directly engaged in carrying out work for the PRP. It is never shared with anyone to enable other organisations to contact individuals. The PRP does not sell data to third parties or allow third parties to sell on data where data is shared.

How do we protect your data?

  1. Your data is held securely on the PRP’s IT system. The database is accessible to a limited number of PRP staff and directly engaged consultants. The PRP ensures that appropriate data sharing agreements and proper systems are in place prior to sharing your personal data with any partners.

Your rights and preferences

  1. The PRP may contact you by post and by email as you have previously consented, unless you request otherwise.
  2. If you no longer want to receive communications by post or email, please email the PRP at admin@pressrecognitionpanel.org.uk. When contacting us, please also specify if you wish to unsubscribe from all communications or from specific communication types or channels.

Other information

  1. The legal basis for processing your minimal personal data for the purposes described above is that it is necessary for the pursuit of our legitimate interests in gathering as many views as possible to inform our regulatory decision-making and for the purposes of informing our annual reports and other communications to Parliament on the successes and failures of the Recognition System.
  2. This Policy will be kept under review. Any changes will be updated on our website and communicated to you as appropriate.
  3. You have the right to:
  • ask us to see, correct or delete the data we hold about you;
  • object to specific data uses, as described above; and
  • object to receiving communications.
  1. The PRP’s Chief Executive is responsible for monitoring compliance with relevant legislation in relation to personal data and can be contacted at admin@pressrecognitionpanel.org.uk. You have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns.
Updated: April 2026 (AGR)

A guide to the information made available routinely by the PRP

Introduction

  1. PRP’s publication scheme sets out the information that we will routinely and proactively make available to the public, and where that information is available. We welcome all comments and suggestions on the scheme.

What information is made available routinely by the PRP?

  1. The PRP makes a significant amount of information routinely available to the public on the basis that we are committed to operating with the maximum degree of openness and transparency in all our dealings – for example, where possible, our Board discussions are open to the public and we publish our Board papers on our website. In the majority of cases, the information that you will be looking for will already be available on our website. Information that is not published under this scheme can be requested in writing and this will be considered in accordance with the provisions of the Freedom of Information Act.
  2. Our core functions and corporate structures are such that some information will not be made available routinely. It may not be appropriate – and in some cases, it may be misleading or confusion – to release information at an early stage, for example during the very early development stage of a new policy or process. Once the Board has come to an initial view about policy proposals, we will either consult on these, and share our thinking with stakeholders and the wider public, in line with our Mission and Approach (if it is a significant policy related to our responsibilities under the Royal Charter) or discuss the proposals further in an open meeting of our Board.
  3. The PRP remains committed to operating openly and transparently in line with its values. Formal meetings and substantive correspondence with stakeholders are documented, and the default position remains that such engagement can be disclosed. However, we also recognise that the timing and level of detail of publication can affect stakeholders’ willingness to engage candidly and, in some cases, may expose them to unnecessary pressure.
  4. For that reason, the PRP will typically report on stakeholder engagement activity six-monthly, once engagement has concluded. Related correspondence may also be reported or published where appropriate, but private correspondence will not necessarily be published routinely in full in every case. This approach is intended to preserve transparency as the principle while allowing the PRP to exercise judgment, including on anonymisation, delay, summary reporting, or non-publication where requested and considered appropriate.
  5. Even though we are not a non-departmental public body, for convenience, this document has been structured according to the seven classes of information in the Information Commissioner’s Model Publication Scheme for non-departmental public bodies. The information that we will make available is grouped under seven classes of information:
  • Who we are and what we do;
  • What we spend and how we spend it;
  • What our priorities are and how we are progressing these;
  • How we make decisions;
  • Policies and procedures;
  • Lists and registers; and
  • Services we offer.
  1. If you would like a hard copy of information available, please contact: us at PRP, Mappin House, 4 Winsley Street, London, W1W 8HF. Telephone number: 020 3443 7072. Email: prp@pressrecognitionpanel.org.uk.
  2. If you ask for information that is available on our website to be provided in paper format, it may be necessary for us to make a charge. For example, if a large amount of photocopying or printing is required, or if the cost of postage of a large volume of paperwork is very high, a charge is more likely to be made. You will be notified in advance of any actual charges.

Is the information available in other languages and other formats?

  1. Most information is available in English. We will also consider, on request, providing copies of material in other languages.
  2. We will supply information in alternative formats where, through reason of disability, standard electronic or hard copy documents may not be accessible. When making a request, please let us know how you would like the information communicated to you – we will do our best to comply.
  3. Please note that providing information in other languages and in alternative formats may take longer than otherwise would be the case.

Our information

  1. Who we are and what we do – organisational information, structures, location and contacts.
Information Format
Role and responsibilities of the PRP

Online

Printed copy from website

Information about our role, function and powers

FAQs

The Leveson Report

Board Members and staff
Organisational structure of the PRP
Information on our internal structure Available on request
The location and contact details for the PRP

Online

Printed copy from website
Legislation
The Royal Charter

Online

Printed copy from website
Organisations we work with

Information relating to the organisations that we work with:

– The recognised Regulator and link to their website

– Details of meetings with stakeholders (unless a duty of confidentiality or exemptions such as freedom of information or data protection apply).

Online

Printed copy from website
  1. What we spend and how we spend it – financial information relating to projected and actual income and expenditure, procurement, contracts and financial audit
Information Format

– Annual report and accounts

– Monthly finance reports

– Annual business plans

Online

Printed from website
  1. What our priorities are and how we are progressing these – strategies and plans, performance – strategies and plans, performance indicators, audits, reviews
Information Format

– Annual business plans

– Annual report and accounts

– Annual reports on the recognition system

Online

Printed copy from website
  1. How we make decisions – decision-making processes and records of decisions
Information Format

Guidance and procedures relating to recognition

Guidance for applicants

Our fee charging scheme

PRP Board’s indicative view on some elements of the Charter

Guidance on cyclical and ad hoc reviews

Board papers provided for consideration at Board meeting

Minutes of Board meetings

Board decision report on IMPRESS

Online

Printed copy from website
Public Consultations – consultation papers and the results of the consultation

Online

Printed copy from website

– Consultation on proposals for recognition

– Consultation on cyclical and ad hoc reviews

– Consultation on amendments to our guidance on cyclical and ad hoc reviews

– Consultation on fees decision report

Online

Printed copy from website
  1. Our policies and procedures – current written protocols, policies and procedures for delivering our functions and responsibilities
Information Format

Board and Executive:

1. Terms and Conditions of Service for Board members
2. Terms and Conditions of Service for Independent members
3. Board remuneration
4. Equality, diversity and inclusion
5. Antibribery, money laundering, fraud, theft and corruption
6. Gifts, hospitality and Expenses
7. Rules and Procedures for Board meetings
8. Audit and Risk Committee – terms of reference
9. Nominations Committee – terms of reference
10. Senior Independent Board member – role and responsibilities

Purpose:

11. Mission and Approach
12. Corporate social responsibility
13. Working in Northern Ireland and Scotland
14. Arrangements for affixing the PRP’s Common Seal

Finance

15. Finance
16. Procurement
17. Scheme of delegation and matters reserved
18. Investment policy
19. Risk management policy

When things go wrong:

20. Disciplinary procedures for Chair and Board Members
21. Complaints handling policy (about a PRP individual)
22. Whistleblowing policy (Board and staff)

Information security/ Business Continuity:

23. Freedom of Information Act policy
24. Data Protection legislation policy
25. Privacy statement
26. Data retention and disposal policy
27. Publication Scheme
28. IT policy
29. Business Continuity
30. Health and Safety
31. Artificial Intelligence (AI) Governance Framework and Policy
32. Data Retention and Disposal Policy
33. Emergency and Disaster Recovery Policy

Online

Printed copy from website
  1. Lists and registers – currently maintained lists and registers
Information Website links

Disclosure logs:

A log indicating what information has been provided in relation to an FOI request

Online

Printed copy from website

Register of interests:

Register of interests of Board members

Register of interests of senior staff

Online

Printed copy from website

Available on request

Register of gifts:

Register of offers of gifts and hospitality provided to Board members and senior personnel

 No offers of gifts and hospitality received
  1. The service we offer – information about the services we currently provide, including leaflets and guidance
Information Format

– Guidance for applicants

– Policy advice

– Preliminary discussions with prospective regulators

– Our fee charging scheme

– PRP Board’s indicative view on some elements of the Charter

– Guidance on cyclical and ad hoc reviews

– Complaining about a recognised Regulator

– Myths and Facts factsheets

– Media releases

– Stakeholder engagement

Online

Printed copy from website or available on request

For further assistance or guidance, please email: prp@pressrecognitionpanel.org.uk or write to us at the following address:

Press Recognition Panel
Mappin House
4 Winsley Street
London W1W 8HF

Updated: June 2026

Purpose and Mission

Definition

  1. The EU Commission defines CSR as “the responsibility of enterprises for their impact on society”. The UK Government defines CSR as “the voluntary actions that business can take, over and above compliance with minimum legal requirements, to address both its own competitive interests and the interests of wider society”.
  2. So CSR is something that we choose to do because we believe it is right to do so.

What is the requirement to develop a CSR Policy?

  1. There is no legal requirement to develop a CSR Policy. However, we believe it is right that we should actively integrate the benefits of CSR in the way we work.
  2. This policy confirms our commitment to acting in a responsible manner and to ensuring our decisions take into account environmental, social, ethical and economic decisions where possible.

Why do this?

  1. CSR forces us to look at the way we work through a different lens. It requires us to be innovative and to see if there is a better, more efficient way of delivering the requirements set out in the Royal Charter. It will help us become more effective and reduce our cost of operating. Reviewing the effectiveness of the way we operate on a regular basis should be part of our continuous improvement cycle with the findings naturally feeding into the state of recognition report we are required to provide annually to Parliament.

Our impact

  1. The PRP was created by Royal Charter. By working with the industry in the area and enabling the implementation of the recognition criteria set out in the Royal Charter we should be able to improve the standards of the press and other news publishers, whilst maintaining their freedom, and at the same time provide assurance and protection to the public.

What are our objectives for 2024/25?

  1. Our objectives for this year reflect our focus on ensuring we have the systems and processes in place to operate effectively as an organisation and meet our Royal Charter obligations. Details are set out in our Business Plan 2024/25 which is available on our website.

What are our values and behaviours?

  1. We will act:
  • independently, using to the full the complete freedom we have from state, government or any other interest, and expressing our views honestly and courageously;
  • fairly, guided by the principle of understanding the public interest, and always putting it first;
  • openly, asking questions, using the widest possible range of evidence available to us to make our decisions, and explaining them clearly; and
  • transparently, wherever possible holding our meetings in public, publishing our papers, and making our meetings formal and documented – ensuring that the public and those we serve can see how we are putting our principles into practice.

What do we spend?

  1. Details of our annual expenditure are available in our annual report and financial statements and past reports are available on our website.

Key Focus Areas

People

  1. We are a very small organisation. It is essential that we recruit the right people, in the right way, to drive our objectives forward. We will review the staffing structure at appropriate points having now implemented and developed operational processes and procedures to assess any applications for recognition and maintain proportionate and efficient oversight of the recognised regulator in accordance with the Charter requirements.
  2. We will ensure that we invest in our staff by providing appropriate training (where identified) to maximise their potential and that we provide a safe, flexible, and open working environment.
  3. In return we expect our staff to:
  • respect and value each other and our differences;
  • be supportive, kind and fair;
  • listen and collaborate;
  • look for innovative ways to achieve better results;
  • be trustworthy and professional;
  • be committed to achieving results;
  • be confident, calm and resilient;
  • be open and share knowledge and information; and
  • enjoy what we do and working together.

Our environmental impact

  1. As a small organisation with low variable costs, we have a very small environmental footprint. We will seek to manage and minimise waste in a sustainable manner and will ensure that the processes we set up and manage and the information we require for recognition do not place unfair burdens on applicants. We store all our files electronically so as to reduce the need to print or retain hard copies.

Use of financial resources

  1. We will:
  • ensure our operating efficiency through continuous evaluation of resources required and reducing our carbon footprint as far as possible;
  • procure sustainably, ethically and effectively;
  • be independent and fair in our choice of suppliers with due consideration to their environmental and sustainability policies and initiatives; and
  • pay suppliers according to mutually agreed terms and conditions.

Review

  1. This policy will be reviewed annually.

Reviewed: April 2026 (AGR)

  1. The Press Recognition Panel is the independent body set up by Royal Charter to ensure that regulators of the UK press are independent, properly funded and able to protect the public. The PRP works in the public interest by supporting and promoting a free press in a free and fair society.
  1. We do this by:
  • deciding whether or not a regulator who applies for recognition complies with the criteria set out in the Royal Charter;
  • making sure, through review, that they continue to meet the criteria;
  • withdrawing recognition if they don’t; and
  • reporting on any success of failure of the recognition system, including the impact of our work.
  1. We will perform our duties:
  • independently, using to the full the complete freedom we have from state, government or any other interest, and expressing our views honestly and courageously;
  • fairly, guided by the principle of understanding the public interest, ad always putting it first;
  • openly, asking questions, using the widest possible range of evidence available to us to make our decisions, and explaining them clearly;
  • transparently, wherever possible holding our meetings in public, publishing our papers, and making our meetings formal and documented – ensuring that the public and those we serve can see how we are putting our principles into practice; and
  • Inclusively: guided by the principles of equality and diversity as an employer, and in the way we work with colleagues and stakeholders, and in the way we conduct out business.
  1. We are committed to operating with the maximum degree of openness and transparency in all our dealings. We will also encourage openness and transparency on the part of other relevant organisations.
  2. We are committed to ensuring that all those who are affected by our work have a say in how we operate.
  3. We are committed to engaging with all stakeholders in a way which respects disabilities and language barriers.
  4. When we consult, we will seek out, and listen to, the broadest range of views. We will speak plainly and promote the widest possible dialogue with all those with an interest in our work.
  5. When we take decisions, we will always consider how regulation can best respond to the developments in the industry on which it will impact, and the changing reality of people’s lives, behaviour and expectations.
  6. We will be challenging where challenge is necessary; we will not seek out controversy but we will speak fearlessly.
  7. Above all, we will ensure that we play a valuable, and valued, role in supporting a press independent of state regulation, but well-regulated in the public interest.
  8. The Statement of Mission and Approach will be reviewed annually.

Reviewed: February 2026 (AGR)

  1. The Royal Charter envisages that the Press Recognition Panel (PRP) will adopt a Common Seal:

    14.2 The Recognition Panel shall have a Common Seal. The Recognition Panel may alter its Common Seal or replace it with a new one.

  2. Under the provisions of the Charter, the Board determines that a document is duly executed by the Press Recognition Panel by the affixing of its common seal.
  3. A document is validly executed by the Press Recognition Panel if it is signed on behalf of the organisation by a minimum of two authorised signatories.
  4. Those authorised to give agreement to the fixing of the seal are the Chair, or any member of the Board and the Chief Executive (and in the Chief Executive’s absence, any two members of the Board).
  5. The seal should be fixed in the presence of a witness who can attest that the relevant authorisations have been granted. This will normally be the Executive Administration Manager.
  6. The sealing will be recorded by the Executive Administration Manager in the register of sealings (an electronic version is saved on the PRP’s secure database). This will record the nature of the document being sealed, the names of the authorised signatories, the name of the witness and the date the seal was fixed.

Reviewed: February 2026 (AGR)

We are committed to receiving and considering applications from across the United Kingdom including Scotland and Northern Ireland. We seek to engage with all relevant individuals and organisations with an interest in our work from across the UK.

When Things Go Wrong

Scope

  1. This policy sets out the process to follow if you are not satisfied with the service you have been given by an individual at the Press Recognition Panel (PRP). Please note that if you have a complaint about the press, you will need to refer it to the relevant press regulator. If your complaint relates to whether or not a press regulator should be recognised by the PRP, or any other matter relating to decisions taken by the Board, please email the PRP.

Stage 1

  1. In the first instance, please contact the person that you have dealt with and discuss your concerns directly with them. They will often be in the best position to understand your situation and give you an explanation as to what has happened.

Stage 2

  1. If you are not satisfied with the response you receive, then you can write to our Chief Executive, who will call for a full report to see whether you have received fair treatment. Please contact the Chief Executive via the Executive Administration Manager.
  2. To help us resolve the issue efficiently and fairly, please provide the following information in your complaint:
  • your full name;
  • your contact details (including address, email and telephone number);
  • how you would like us to contact you in relation to your complaint;
  • your relationship with the PRP;
  • a detailed description of your complaint, what you think went wrong, including dates and times of any specific circumstances;
  • any details of what you have done to try and resolve the issue so far;
  • what you think we should do to resolve the matter;
  • any issues around confidentiality in relation to the individual(s) you are complaining about; and
  • any relevant documentation underpinning your complaint.
  1. The Chief Executive will review the information you have provided and may also gather further evidence as required. This may include asking you for further information or speaking to other individuals involved.
  2. We will normally tell the individual to whom the complaint relates that a complaint has been made against them unless there is a need to maintain confidentiality.
  3. Once the Chief Executive has completed the review, we will inform you of the outcome. If the complaint is upheld, we will explain the steps we are taking to put things right. This may include reviewing a particular decision and/or putting measures in place to rectify or remedy the position and/or avoid the circumstances giving rise to the complaint from happening in the future.
  4. If your complaint is not upheld, we will explain why. If you remain dissatisfied, or if your complaint is about the Chief Executive, you may refer the complaint to Stage 3.

Stage 3

  1. At Stage 3 of our complaints process, the Chair of the Press Recognition Panel will review the report prepared for the Chief Executive and the decisions taken so far and may also seek further evidence. The Chair will respond to you with the outcome of the review detailing whether your complaint has been upheld or not, and why.
  2. You can contact the Chair via the Executive Administration Manager.
  3. If your complaint is about the Chair, you may refer your complaint to the PRP’s Senior Independent Board member. Please contact the Senior Independent Board member via the Executive Administration Manager.

Timeframe

  1. You should try to make your complaint as quickly as possible. If you are complaining more than 3 months after an incident you should explain why your complaint has been delayed. We will always consider complaints brought within this period, but will only consider those outside if good reasons are given for the delay. If you wish to take your complaint to either Stage 2 or Stage 3, however, we will expect you to do so within one month of the original decision.
  2. We will treat your complaint in confidence and will investigate it carefully as quickly as possible. Every effort will be made to send a full and clear reply within 10 working days of your complaint being received. If we cannot investigate your complaint fully within that time, we will let you know and keep you informed of progress.

Updated: February 2026 (AGR)

Introduction and scope

  1. The Royal Charter provides (para 6.2) that: ‘If the Board is satisfied (which shall require a majority of two thirds of the Members entitled to vote to concur), that a Member is unwilling, unable or unfit to discharge the functions of a Member of the Board under this Charter, that Member shall be duly dismissed and notified in writing of this fact, together with reasons. The Member concerned shall not be entitled to vote on this matter and the Board may make further provision as to the operation of this paragraph under Article 6 of the Charter.’
  2. This procedure has been prepared to give effect to the provision above and has been approved (and will be periodically reviewed) by the Board.
  3. This disciplinary procedure is also to be used in the event of an allegation of personal misconduct or impropriety or a suspected breach of duty by the Chair or any other Member of the Board.
  4. In accordance with paragraph 6.1 of the Royal Charter, any Member of the Board may resign by giving notice in writing to the PRP.
  5. The PRP has a separate Complaints handling policy about an individual at the Press Recognition Panel.

Legal representation

  1. At any stage of an investigation into allegations made against a Member, the Member is entitled to legal representation. The Member will be reminded of this entitlement to advice at each relevant stage of the procedure. If the Member chooses to be legally represented, they must inform the Chair in writing of the name and address of the legal representative.
  2. Legal representation will be at the Member’s expense. However, depending on the outcome of the investigation, some or all such costs may be reimbursed at the discretion of the Board.

Procedure for investigating alleged breaches of duty in relation to Members other than the Chair

Preliminary consideration

  1. If the Chair becomes aware of issues relevant to this policy relating to a Member, the Chair must:
  • inform the Member in writing of the details of the issue and invite him/her to submit written comments within 14 days, or such other period as may be specified; and
  • notify the full Board that they have done so.
  1. Following consideration of the Member’s written comments, if the Chair is satisfied, on the basis of all the information available to them, that any concerns raised are manifestly unfounded, no further action will be taken. The Chair must inform the Member, the full Board and any person who made a relevant allegation of their decision.
  1. If the Chair is satisfied, on the basis of all the information available to them, that the issue raised is not manifestly unfounded, they must immediately write to the Member concerned:
  • stating that the issue will be investigated;
  • enclosing a copy of these procedures;
  • setting a date for the individual to meet the Chair (preferably within 14 days from receipt of the letter); and
  • informing the individual of their entitlement to be accompanied or legally represented at the meeting and at any subsequent stages of the investigation.

Meeting with the Chair

  1. The Chair will meet the Member concerned to discuss the alleged issue and the Chair will then decide the appropriate course of action to be taken. The Member may be accompanied or legally represented at the meeting by a person of their choosing.
  1. After the meeting, the Chair, having regard to all relevant factors, including the outcome of any further investigation they may consider necessary, will submit a report to the full Board in which they may recommend that the Board should take one or more of the following courses of action:
  • dismiss any allegation and/or end the consideration of the issue;
  • direct further investigation of any allegation/issue;
  • suspend the individual’s appointment to the Board pending further investigation;
  • terminate the individual’s appointment to the Board; and
  • direct such other action as the Chair considers necessary.
  1. On the basis of the report prepared by the Chair, the full Board will determine the matter. In accordance with the Royal Charter, the Board’s decision shall require a majority of two thirds of the Members entitled to vote to concur. The Member concerned shall not be entitled to vote on this matter.
  2. If the Board suspends the Member’s appointment, it may direct whether such suspension is to be with or without remuneration.
  3. If the Member’s appointment is terminated, the Member will be notified without delay and in writing, together with reasons for the Board’s decision.

Further investigation

  1. If the Board directs further investigation, it may appoint an Investigating Officer. The Investigating Officer may be an official of the PRP or any other person at the Board’s discretion.
  2. Subject to any whistleblowing arrangements the PRP has in place, the Investigating Officer may seek any further evidence and interview any person, as they consider necessary.
  3. The Investigating Officer must report their findings of fact to the Member concerned and invite their comments within 14 days, or such other period as may be specified. At the conclusion of the investigation, the Investigating Officer will report their findings together with the Member’s comments, if any, to the Board. The Investigating Officer may also make recommendations to the Board.

Notification of decision

  1. After consideration of the Investigating Officer’s report and any recommendations and of any comments made by the Member, the Board will determine the matter. The Board’s decision shall require a majority of two thirds of the Members entitled to vote to concur. The Member concerned shall not be entitled to vote on this matter.
  2. If the Member’s appointment is terminated, the Member will be notified without delay and in writing of this fact, together with reasons for the Board’s decision.
  3. At the conclusion of the investigation, the Board may publicly announce its final decision, subject to carrying out a Data Protection Impact Assessment (DPIA). Any such announcement would normally be brought to the attention of the Commissioner for Public Appointments.

Procedure for investigating complaints made about Members in their professional capacity

  1. If a complaint in relation to the conduct of a Board Member in a professional or personal capacity is made to or by a professional body or prosecuting authority, they should notify the Chair without delay and the matter will be declared at the next Board meeting.
  2. If the Chair considers that the issue is one that potentially falls within the scope of this policy, they will act in accordance with the requirements of this policy.

Investigations relating to the Chair

  1. Any allegation or concern relevant to this policy and relating to the Chair should be made to the Senior Independent Board member. The Senior Independent Board member will inform the Chair of the issue as soon as possible.
  2. Any investigation relating to the Chair will be carried out by the Senior Independent Board member, on the Board’s behalf.
  3. The procedures set out in this document will apply, save that references to the Chair in the conduct of the investigation will be substituted by ‘the Board’ (or any person the Board directs).

Updated: February 2026 (AGR)

Making a Disclosure in the Public Interest

Introduction

  1. The Press Recognition Panel (‘the PRP’) is committed to the highest standards of openness, probity and accountability. An important aspect of accountability and transparency is a mechanism to enable the Board and staff (defined as employees and all those working with and for the PRP) to voice concerns in a responsible and effective manner. The PRP promotes a positive and open whistleblowing culture where individuals feel confident that concerns can be raised and dealt with quickly and that they will be protected for doing so.
  2. It is a fundamental term of every contract of employment that an employee will faithfully serve his or her employer and not disclose confidential information about the employer’s affairs. However, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed internally without fear of any detrimental treatment or victimisation, and there should be arrangements to enable this to be done independently of line management. We also encourage all those that work with us to report any suspicion of slavery or human trafficking without fear of retaliation.

Scope

  1. The Public Interest Disclosure Act 1998, gives legal protection to employees who reasonably believe that they are acting in the public interest and where the disclosure falls into one or more the following categories:
  • a criminal offence;
  • the breach of a legal obligation;
  • a miscarriage of justice;
  • a danger to the health and safety of any individual;
  • damage to the environment; and
  • deliberate concealment of information tending to show any of the above five matters.
  1. It should be emphasised that this policy is intended to assist individuals who reasonably believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the PRP, nor should it be used to reconsider any matters which have already been addressed under other procedures.
  2. It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.

Confidentiality

  1. It is possible for you to raise your claim anonymously if you wish to do so. However, this may mean that it is difficult to investigate fully if you haven’t provided us with enough information.
  2. The PRP will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

How to raise a concern internally

  1. You should raise any matter of concern, serious or otherwise with the Chief Executive Officer (CEO) or Chair of the PRP Board. If the matter concerns the Chair or the CEO, you should speak to the Senior Independent Board Member.
  2. When raising your concern, it is helpful for you to provide an explanation with as much detail as possible including dates and times of incidents, any eyewitness details and any supporting documents that you have. You do not need to wait for proof when reporting a concern. You only need to have a reasonable belief that wrongdoing has occurred, is occurring or is likely to occur. It is not for you to investigate or prove that your concerns are justified, as that is the responsibility of the PRP.

How to raise a concern externally

  1. Where attempts to raise matters internally have been unsuccessful or exceptionally, you feel you cannot raise the concerns internally, you may consider raising the matter externally. If an individual decides to blow the whistle to a ‘prescribed person’ rather than their employer, they must make sure that they have chosen the correct person or body for the issue. The Department for Business, Energy & Industrial Strategy has published a list of the prescribed persons and bodies who an individual can make a disclosure to. There is also a brief description about the matters that can be reported to each prescribed person: https://www.gov.uk/government/publications/blowing-the-whistle-list-of-prescribed-people-and-bodies–2

What happens next

  1. The person who you raise the concern to will listen and consider your concern in full and determine whether any action is needed. This may include reporting it to the Audit and Risk Committee.
  2. We will try to keep you informed, in writing, about the action that we are taking in relation to the concern including how we propose to deal with the matter, whether we need further assistance from you, any action that is taken and the outcome of the investigation. We will try to keep you informed of progress and where possible provide you with an update within 28 days. However, we may not be able to provide you with all of the details of the investigation, for example where we have a confidentiality duty to the parties involved.

Reviewed: February 2026 (AGR)

Ways To Connect

Get in touch for more information and updates.

BOARD MEETINGS

Papers and reports from our Board meetings are available online.

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