PUBLIC SERVICE BROADCASTING: BOTH FREE AND ACCOUNTABLE DENIS McQUAIL Abstract As public broadcasting in Europe has declined in relative terms in the overall supply of television broadcasting, its activities have become more subject to scrutiny, both by regulatory authorities and by its competitors. The result is a threat of greater control and less genuine independence. In some countries, the price exacted for continuing financial support is increased accountability according to more narrowly defined criteria of performance. The central argument of this article is that public broadcasting should in principle enjoy the same freedom to publish as other media, within the limits of its special legal and constitutional position. Further, freedom should not be an obstacle to meeting social responsibilities and may even contribute to this goal. This view is supported by a closer look at the nature of media accountability, which has to be clearly differentiated from regulation and control. Denis McQuail is emeritus professor, University of Amsterdam, and visiting professor at the University of Southampton, e-mail: 106233.3000@compuserve.com. no fN no no m o o fN O > A 3 a o e m Public broadcasting in Europe is increasingly subject to pressures from political and commercial forces that often reinforce each other and work in the same direction (Kelly et al. 2003). Fundamentally at issue is the justification for maintaining a public sector in the spectrum of electronic media in "free" societies (Harrison and Woods 2001). Arguments in support of public broadcasting tend to emphasize the informative and educational role of broadcasting, as against the more entertaining role of commercial media. This opens the way to demands for external control of publication policy and detailed assessments of performance in respect of the agreed role. The same standards are not applied to commercial competitors, who may even use this line of approach as an excuse for neglecting their own social responsibilities. The position of this article is that public broadcasters should have rights as publishers to interpret their own role without undue outside interference and that commercial media cannot claim any general immunity from normative expectations of service to society. The arguments that follow are largely drawn from a recently published work by the present author (McQuail 2003), although here presented in summary form. The Contested Idea of Media Responsibility Although this article focuses on public broadcasting, it begins with a wider view of what society can legitimately expect from its media in terms of responsibilities to meet various public objectives. The view that mass media, broadly defined, have some obligation to serve the society in which they operate is for some an axiom that hardly needs explanation. For others, however, it is an aberration that has to be contested all the more strongly because of its seeming plausibility. The first position goes with an outlook that treats the media as an integral part of a modern social system, to which they make a necessary contribution. The alternative view holds that true freedom of expression and publication (of the press in all its forms) implies a lack of obligation to meet any outside claim, especially any claim that is made in the name of the society or state and therefore backed by force as well as authority. In between there are many and varied positions and quite a few different arguments for or against each one. A distinction can be made between a general institutional commitment to the public good on the one hand and the freedom of individuals (or particular organs of the press) to publish as they wish. The media regularly accept an obligation to their audiences and clients (for instance to provide information or a platform for public expression) that can be interpreted as services to the society more broadly, again without contravening any principle of liberty. There is, in any case, no consensus on the content and value of any particular "responsibility to society," since there is little agreement on what the public interest might consist of or on how it is to be recognised (Smith 1989; Downs 1962; Held 1970). While very general utilitarian notions define the public good as what is best for most people in the longer term, a case can also be made for defining public interest as what the majority of the public wants at any given moment (Fowler 1982). This position is typically associated with a preference for free market provision of services, and is invoked to contest the notion that public broadcasting is uniquely or best designed to serve the public interest. Libertarians usually view any attempt to saddle the media with social responsibility obligations as an interference not just in freedom of publication but also in the freedom of the marketplace and in the rights of ownership (see Lichtenberg 1990). The debate is complicated by the elasticity of the notion of obligation and the existence of several alternative definitions. Obligations are not only strong or weak, voluntary or allocated, but they can also be of varying kinds: moral; ethical; social; or legal. Obligations to do good are different from requirements to avoid harm. These variations are discussed in some more detail below, but there is yet another dimension of differentiation to complicate matters, which relates to differences in the kind of media we are talking about. Of particular relevance is that fact that from its beginning, broadcasting has been subject to an exceptional degree of formal regulation and informal supervision, setting it apart from print media. Much of the thinking about the possible social responsibilities or "functions" of media dates from the early days of print media when newspapers and periodicals played a leading part in the rise of democracy and of liberal economic institutions. In the much more complex media system of today, the core tasks of the early press are still important in their support for the political, judicial and economic processes of society, but they are embedded in a much wider range of services, especially in the sphere of entertainment and publicity and also in commercial activities. As a result, the greater part of all media activities are unambiguously carried out "for profit" according to market rules, or consist of cultural or informational services to many individual consumers who have to be the sole judge of adequacy of performance. The Particular Position of Public Broadcasting The public broadcasting media sector, where it exists in democratic societies, has its own special location and identity within the nexus of variable conditions that has been indicated. The expectations that attach to it vary a good deal from place to place and are not without ambiguity, except on one basic point. Public broadcasting systems have been created and maintained to serve society and provide for some social needs, usually as determined by way of the democratic political system. They are allocated certain responsibilities and they are required to serve the "public interest" in ways that go beyond what market forces can determine. They are also required to render an account to the public of their conduct in respect of these responsibilities. However, this is a general statement that conceals much diversity of practice and freedom of editorial decision-making. As a result, there continues to be a good deal of uncertainty as to what might count as an acceptable level of performance. It is arguable that public broadcasting is not uniquely different from private broadcasting in respect of the content of possible responsibilities to society, only in the degree to which these can be enforced. This being the case, it is necessary to consider the case of public broadcasting within the larger context of relations between media in general and the society in which they operate. The Variable Sources of Media Obligation In order to appreciate the nature of what public broadcasting might be considered to owe to society, we need to look first at what the media in general owe to society. All forms of publication by way of mass media have a public character and a public role, whether chosen or not, and determined by a number of institutional and contextual factors. A summary view of the different sources of media obligation to society includes: • Social and political theory • The public as audience • The public as citizens • The media market • The state and its agencies • Interested parties • Professional theory and practice Most generally, ideas of what contemporary mass media owe to society are rooted in the history of democratic states, especially in the western liberal tradition that has freedom of expression as its foundation stone. Democratic political theory posits that the self-government of states by its people will require the free circulation of information and ideas relevant to the issues on which collective decisions have to be made (see Keane 1991; Schultz 1998). This means: access for individuals to make claims, present proposals and stand as candidates for office; space for the presentation and discussion of diverse ideas; unrestrained opportunities to assemble and to participate in public debate. The media as a whole are expected to broadly reflect the varied conditions and interests of a society. They should provide channels of communication connecting governors and governed horizontally as well as vertically. For governments they are a source of intelligence and "feedback," for the people, they are an important means of holding governments to account for their actions Aside from such public tasks assigned by normative media theory, publication is likely to be judged, albeit variously, according to principles of freedom, truth and their contribution to social and cultural order (McQuail 1992). The variation lies in where the emphasis is placed, especially as between contributing to diversity, innovation and critical opposition or alternatively to continuity, social harmony and public order. Theories also differ according to whether they emphasise the virtues of negative freedom (lack of restraint) or those of positive freedom (intervention to secure access and diversity; Glasser 1986). In practice this offers a basic choice between a libertarian view (the free marketplace of ideas) and some form of social control designed to secure fairness and diversity in the face of market tendencies to concentration and exclusion. There are differences within the libertarian camp according to whether freedom is the absolute value (the deontological view), or what matters more is what freedom actually delivers (Schauer 1982). Equally, within the "democratic" camp there is also a wide range of views about the degree and kind of restrictions that can be tolerated and about the means for implementing the "will of the people." Intervention can be "statist" and backed by law, or it can take the form of social pressure and small-scale and grass root initiatives. Public broadcasting is a clear product of the interventionist, social-democratic and statist form of theory, designed to fence off an area of the media system and the public space for occupation by forms of media that are subject to non-market criteria of performance in some respects and required to deliver some of the ben- efits to society (of the kind named above) that advocates of the "free market place of ideas" also expect. The "positive freedom" public broadcasting is supposed to deliver is freedom from the "laws" of the market place and freedom for access, diversity and service to unprofitable but socially desired communication objectives. The important point is that these objectives, derived from a common inheritance of ideas about a good society, are largely shared with other sectors of the media system, including the press and private broadcasting (Nerone 1995). Much the same general argument applies to each of the other sources of media obligation. The public as audience exerts a continuous but also changing demand on the media to meet various expectations and to deliver on promises of type and quality of material. This obliges the media to meet a variety of cultural and informational needs, in the first instance of individuals, but open to interpretation as meeting collective social needs. The pressure to meet audience needs is not experienced very differently by public broadcasting than it is by their commercial competitors, especially in the case of television which until now at least has been largely free at the point of delivery to viewers. Theoretically, the audience for public television has some more means of complaint or redress because of the legal requirements of public service, but in practice this may not make much difference and the kind of demand by the audience is much the same, for public and private providers. When the public is considered as the body of citizens rather than the audience a somewhat different situation arises. Public broadcasting does have an obligation to listen to the opinion of "the public" in whose interest it operates, but not in respect of the kind of provision that is called for and the means for securing it. Its obligation to the public as audience is no different, or at least no greater, than that of private broadcast media. It does have some obligations that go beyond the scope of what audiences might demand, including the provision of some kinds of content for which there is very little of an audience at all. This means that it cannot allocate its time only in proportion to the amount of demand. While public television, by virtue of its means of funding and obligations, escapes the immediate pressure of the market, especially the need to satisfy criteria of profitability and short-term popularity, the remission is only partial. There are some pressures to succeed in the audience market, certainly in the longer term, arising from professionalism, ambition and political factors. Where income is partly dependent on advertising (as it is in most public television), the same constraint exists as elsewhere. In other respects, the same extended media market determines the costs of production and the capacity to engage in activities that are considered to be in the public interest. The influence of the state is certainly greater on public broadcasting than on other media, but it is also mitigated by several factors. These include the various provisions for guaranteeing a necessary degree of political independence, the counterbalancing of external political pressures, the security of sources of income and the protection from market forces. Apart from these matters, all broadcasting (whether public or private) is normally subject to positive requirements in the matter of service that are enforceable. On the other hand a good deal of regulation of television is increasingly applied to the sector as a whole and by the same agencies of control or accountability. In so far as the law constrains publication or holds publishers responsible for the consequences of their actions, no distinction is made. Public broadcasting has to observe the same standards of decency, avoid the same harms. It has more obligations rather than different ones. Finally, public broadcasting is staffed by the same professionals as other media and is equally, but not necessarily more, constrained to meet standards of professional quality and to obey the same codes of practice and ethics that apply elsewhere. A number of obligations to serve society are supported by professionalism and enforced by self-regulation. These relate specially to the quality of information needed for engagement in public affairs and the democratic process and also to fairness and diversity in the coverage of events, opinions and beliefs. Taken together it is hard to deny that public broadcasting is much less distinctive in its aims and obligations (and thus its performance) than it is in its form of ownership. It follows that the means of accountability that are appropriate are also not very different, despite the additional avenue that is available in the form of direct public access to the means of control by enforcing obligations. Lines of Accountability One way of summarising these remarks is to say that media are typically beholden to a range of potential claimants that can call them to account for acts and omissions, according to diverse expectations. The operating environment of all media is occupied by a set of actors with some power of constraint or potential for influence on the media. Although the "power of the media" is often stressed, they are also at the receiving end of power and influence. Attempts to control or influence the media have varying degrees of legitimacy, but they can be effective independently of that factor. In general the media may owe responsibility, with some legitimately entailed accountability, to the following: their owners; those sources to whom they have contractual ties or other obligations (including advertisers, but also authors, performers, etc.); relevant regulators and legal authorities (in the end governments); society (as expressed in public opinion, but also as embodied in social institutions); all those whose rights and interests are affected by the media; those to whom promises of service have been made (which often includes their audiences). The situation described is sketched in Figure 1. Figure 1: External Lines of Media Accountability Owners Artists/Performers Audience member(s) Voices/advocates Social institutions Clients MEDIA Referents Sources Pressure/interest groups Public Regulators Public Opinion This representation seems to emphasise the high degree of dependence of the media on outside agencies and actors. In fact, there are many pulls and pushes involved that do not all work in the same direction and may cancel each other out. The linkages represented are often interactive, reflecting a mutual state of depend- ence. As a result, there is no accumulation of external pressure, but rather a confused and sometimes unequal struggle in which the media may hold the balance of power or have a free hand to decide which partners to favour. The "lines" of accountability can have different strength and direction in different cases. Most direct influence and therefore the strongest claims to accountability are likely to come from those on whom the media depend most directly for their continued operation. This varies a good deal according to the medium and media system involved. All media may depend on their audiences, but not usually directly and immediately. Private media are most likely to respond to their owners and major clients. Public service broadcasting inevitably has stronger obligations to account to "society," whether in the shape of actual regulators or as the ultimate owners. The claims of social institutions and of public opinion are also somewhat stronger. But non-public media are not free from the same set of pressures and public broadcasting media have to weigh what they owe to "society" as indicated against other obligations, including audiences, sources, those on whom they report and, where there is private finance, also to clients. What Responsibilities Do Media Have? This question is intended to uncover the content of possible obligations in general terms. Following what has been said of the origins of responsibilities, it is clear that there are several different kinds and different ways of identifying them. Most obviously, there are certain obligations laid down in law, regulation or contract that all media have to respect, even if they are of a minimum kind and negative in formulation. Public broadcasting systems are unusual in having enforceable positive requirements to meet particular goals, such as the supply of full and balanced news and information or the meeting of various educational and cultural goals. Sometimes very specific performance criteria are laid, especially as they relate to certain categories of (minority) content, timing of transmission, balance and diversity of access, service to minorities, origins of content, etc. Some of these, as well as many other kinds of responsibility are accepted by other media as well, arising from the various sources indicated at the outset. For present purposes, however, it is helpful to describe media responsibilities in terms of the main types of issue on which they might be called to account. These issues can be considered as having a more private or more public character, as shown below. But there is another dimension, which relates to their positive or negative character. The media are expected to prove certain benefits for their society, and they are expected to avoid various kinds of harm, that are not always the reverse of the benefits. In general, we can expect that requirements to avoid harm will apply with more force and to all media, while expectations of benefit will be less enforceable and more variable from one medium to another. In the nature of public broadcasting, they are more likely to face non-optional positive requirements. The more public and collective issues of public concern on which media may be called to account include: • Order and security • Public mores • Cultural quality • Needs of government and the justice system • "Public Sphere" benefits • Human rights and international obligations The entries need only a brief explanation. In respect of order and security, media have the same duties as citizens to observe the law and to cooperate with legitimate activities directed at combating criminality. They are also subject to the same requirements as others in respect of defence and security matters. However, their potential obligations go beyond those of citizens because of their alleged capacity to stimulate certain kinds of crime or disorder, albeit unintentionally. This applies to content that might, for instance, activate violent or criminal tendencies, glorify crime or "teach" criminal methods. By spreading certain kinds of (mis)information media have the power to cause alarm or panic and there are many ways in which media, whatever their motives, might in their pursuit be of assistance to "enemies of the state," whether within or without. This may be a set of issues, where the obligations are to avoid harm, but they can easily be expressed as positive prescriptions for law-abiding or loyal media. The issue of public mores relates primarily to expectations that media will respect reigning conventions of decency and morality especially in matters of sex, portrayals of violence and language used. Matters of taste and respect also arise in relation to illness, disability and religious sensibilities (e.g. blasphemy). Here the issue is not of harm, but of offence or shock and the responsibilities are negative rather than positive. Issues of cultural quality are more likely to be prescriptive as well as diverse, with media being expected to promote or support the national language and culture as well as to meet certain artistic and educational standards. An issue of cultural provision for minorities within the society can also arise. What are referred to as "public sphere benefits" are mainly those services of information and opinion-formation that support democratic political processes and an open society. The "benefits" come mainly in the form of extensive flows of reliable, diverse and relevant information, opinion and debate, including criticism and accountability in the "court of public opinion." These are clearly positive responsibilities, but coupled with an implicit warning against the misuse of the power to inform, as in bias, distortion, propaganda, deliberate omission and sensationalism. The state cannot claim much help from the media for its normal activities on any other grounds than are determined by the needs and interests of all citizens. Even so, the adequate working of the justice system in most open societies depends on some services of information and publicity as well as on a degree of restraint from the media, in order to ensure fair trials. On the whole, the issue here is one of responsible use of the power of publicity held by the media. The last entry in the list refers to issues of human rights, which arise where publicity harms the reputation of minority or other groups, or leads to prejudice and discrimination on whatever grounds. There is an international dimension to human rights issues and there also questions about the role of the media in the promotion of peace and international justice, or conversely in warmongering and encouraging hatred and contempt of foreigners. The main issues of a more private nature where accountability is likely to arise include: • Consumer needs and satisfactions • Individual rights and interests • Property and economic interests • Harm to individuals • Specific moral and ethical questions The first relates to the general character and content of media services that are designed to meet the needs of audiences. The quality of provision can be assessed according to a range of criteria, some more or less objective, others subjective. More contentious and also more rare are the cases where individual rights can be violated or interests damaged by media, most especially by defamation and negative publicity or by invasion of privacy, without much chance of any equivalent response. Individual rights include matters to do with intellectual property and copyright. Harm to individuals can be caused in a number of ways, for instance by reports that lead to their being vilified or targeted, or where individuals are provoked to attack others under some media influence. Finally there are a number of specific issues of media conduct and performance where media may be called to account, without their being any victim, for instance concerning plagiarism, the protection of sources, the means used to obtain to secure confidential information, breaches of confidence, etc. It is evident from this description that virtually any accountability issue can arise in relation to any mass medium, irrespective of its form of ownership or organisation, placing public broadcasting in precisely the same position as regards the content of any accountability claim. More Accountability, Less Freedom? Before proceeding, this question has to be answered and to do so requires clarification of the meaning of terms that have already been liberally used, especially the terms "responsibility" and "accountability" that remain in dispute, despite increasing theoretical attention (see Dennis et al. 1989; McQuail 1997; Plaisance 2000; Pritchard 2001). The two key words are often used interchangeably and defined in terms of each other, with common core idea of "answering" for something and to someone. The case of media responsibility to society cannot be adequately understood without clearly distinguishing between them. The key to the difference has been succinctly put by Hodges (1986, 14) as follows: "The issue of responsibility is as follows: how might society call on journalists to account for their performance of the responsibility given to them. Responsibility has to do with defining proper conduct, accountability with compelling it." This statement makes it clear that responsibilities principally refer to prior or established obligations (of various kinds, origins and strength) and accountability to a subsequent process of measuring performance against the standard stated or implied in the "obligation." Although clear enough, the statement also opens up several other issues, most centrally the extent to which journalists have any binding obligation, which the quotation implies. The notion of "compulsion" also sits uneasily with the notions of press freedom and journalistic professionalism. This takes us to the core of the problem of accountability, which is the apparent inverse correlation between freedom and accountability. The contradiction seems especially marked in the context of publication, where the principle of freedom of speech rules out censorship and punishment for speech as illegitimate, except under a limited number of circumstances. This is not just a theoretical issue, since virtually all modern efforts to make the press more accountable for alleged breaches of responsibilities on many of the issues listed above have been countered by an appeal to a more or less absolute protection of freedom of the press or media. The motives for such resistance may often be questionable and appeal to principle is sometimes self-serving, where large media corporations are pitted against democratic governments or many powerless victims of publicity. It may appear that public broadcasting escapes the dilemma of achieving effective accountability without violating basic freedoms, since its freedom is constrained, by social contract as well as law, and dependent on certain agreed standards of performance. However, as we have seen, public broadcasters are also publishers with obligations to other actors and agents, including news sources, artists and performers. Beyond the areas of limited freedom (especially in relation to the ultimate interests of the state and the requirements of diversity and balance) they are in much the same position as any other publishers in relation to most of the issues named above. Increasingly, constitutional guarantees of freedom of the press have been amended to include broadcasting along with the newspaper press. Given the extensive network of formal and informal obligations that all media are enmeshed in, we have to answer the question in the sub-heading above in the negative. In the real world, there is no freedom totally devoid of accountability and there have to be ways of reconciling one with the other if we cling to the principle of freedom of expression and the press. In order to take the matter forward a closer look at the key terms is called for, in the search for effective means of accountability that would be consistent with the notion of responsibility (especially to society or the "public interest") and also with essential principles of free expression. In conducting this search, it becomes apparent that the problems encountered are not unique to public communication. There are numerous contexts where legitimate action affecting the interests of others is subject to claims and limitations and efforts to keep it within the boundaries of what is acceptable or normal. This applies in business relations, where freedom of the market has become surrounded by various constraints and in government where legitimate actions of the state can be questioned and countered by formal and informal means of accountability. In many contexts of professional practice, obligations are accepted, typically accompanied by defined forms of accountability for performance. It is not least in evidence in interpersonal relations where our "free" dealings with others are subject to many informal constraints and requirements to maintain relations by give and take (see Giddens 1984; Semin and Mansfield 1983; Buttry 1993). Meanings of Responsibility It is clear from the variety of sources of potential obligation to some version of the public interest that there is quite a variety of types of responsibility. These have been characterised in different ways, with a good deal of agreement on the difference between obligations that are legal, moral, ethical or social in character, each with its own more or less given forms of accountability. Legal obligations are inescapable and subject to formal processes of complaint or redress, but have limited application to the media for most of their operations. By definition they are externally defined, backed by the forces of society and account has to be rendered as determined by others. Moral obligations are, by definition, self-chosen and personal and unlikely to be subject to external accountability compulsion. Ethical obligations overlap to some extent but are more appropriate to the circumstances of an organization or collective entity. They are likely to be self-determined, although not idiosyncratically so, and usually go with some forms of professionalism and thus the means of self-regulation. Social obligations stem from the general requirements of society and community, are open to interpretation and vary in the force with which they are experienced. For the most part they are "enforced," if at all, by the pressure of public opinion and by the relative esteem or disdain that attaches to various failings on the part of media. This variation according to type of obligation is related, as indicated, to the source and strength of any obligation. To some extent, the variable of strength depends on whether the responsibilities at issue are voluntarily adopted, assigned (as in the case of regulated public broadcasting) or contracted in some way, especially in a market relationship with content supplier, client, distributor or the audience. A somewhat finer discrimination is needed, however, to make the connection with appropriate forms of accountability. With this in mind, the most relevant types of responsibility of media are described as follows: Contractual or Promise-keeping. This relates mainly to responsibilities to audiences made in the form of promises of kinds and standards of informational and cultural services. Media may also "promise" certain benefits to society and contributions to the public good. While contracts of the kind laid down in licences for transmission or media laws are formal commitments, many of the expectations that media give rise to amongst the public and other social institutions are informal and matters of good faith. Even so, in some respects of service to the "public interest" there may be a case of an "unwritten social contract." Some of the justifications for press freedom and in cases, privilege and protection are based on an understanding that there will be some benefits to the public, especially in cultural and informational matters and support for other important social processes. Some media and some occupations subscribe to codes of conduct that promise compliance with certain standards relevant to the accountability issues outlined. Fulfilling the Tasks of an Occupational Role. It is obvious and not trivial that the work of the media is largely carried out by persons with varied professional, craft and creative skills and their activities can be treated as responsibilities, subject to accounting for performance. In this case, the primary form of accounting is likely to be by way of either internal media management, or professional self-regulation or peer group pressure and competition. Meeting External Obligations. Responsibilities under this heading include all legal and regulatory requirements that apply either to media in particular or to all citizens. Some of the issues outlined earlier falling within the scope of this form of responsibility, for instance in relation to defamation, incitement to violence, undermining the justice system. Having Causal Responsibility. A significant area of debate about media responsibility relates to the issue of liability for harm caused to individuals or society in general by some types of publication. The media here are treated in their capacity as potentially powerful agents that can affect behaviour and attitudes, whether intentionally or not, giving rise to claims of harm. The media may be called to account for inciting or condoning violence, lowering moral standards, causing panic, reducing respect for authority and many other unwanted effects. The failure to achieve certain effects, for instance in the sphere of public information, leading to public ignorance, apathy or cynicism may be treated under this heading. Having Moral Responsibility. While moral responsibility has been mentioned above as a matter of the conscience of the many individuals in media, there is also a collective aspect where it may be interpreted as responsibility, not for direct harm but for general and long term consequences, usually unintended, of publication practices. For instance racial prejudice, xenophobic attitudes, denigration of women or undermining the democratic process might be attributed to systematic patterns of bias or omission in news coverage over time. The responsibility for consequences of this kind is unlikely to be accepted by the media, and cannot normally be dealt with in the same way as liability for direct effects, but media are unlikely to escape some attribution of responsibilities of this kind by their critics. Meanings and Types of Accountability Despite the overlap with responsibility it is possible to offer a distinct definition of accountability, although several different paths for realising it in practice are available. Pritchard (2000:2) defines it as follows: "Media accountability is the process by which media organizations may be expected or obliged to render an account of their activities to their constituents." He describes an account as "an explanation of justification of a media worker's or a media organization's conduct." In this view it is a process which follows on from but it is distinct from the normative prescriptions that comprise possible responsibilities. The process at its simplest, according to Pritchard, is one of "naming, blaming and claiming." A problem is named (in terms of the accountability issues mentioned above); blame is attributed to some media content or organization; a claim is lodged for justification, apology or compensation. An earlier version, by Christians (1989, 40) describes accountability as a "reckoning properly requested and given, a statement explaining conduct to legitimately designated partners." Brummer (1991, 14) points out that rendering an account has to be made to someone, for something, on the basis of certain criteria and with varying degrees of enforceability. He also notes that the partners in an accountability relationship are those to whom a promise is made, those to whom a legal duty is owed, those who are affected by one's actions and those who have the power to affect oneself in return. In the case of mass media, accountability can be owed at different levels, ranging from the individual communicator to the media organisation or even the institution, to the audience, clients, regulators, owners and those materially affected by publication. The forms in which accountability is made are diverse, depending on the case and the context. The media may employ or be required to undergo any of the following means of accountability: • Provision of information, reporting about performance and publishing audience research; • Voluntary response to claims and complaints, in the form of apologies or explanations; • Formal processes of self-regulation, involving some independent adjudication; • Legal action in the courts; • Submission to the judgement of the market, at the hands of audience or advertisers; • Public review, criticism and debate. Accountability forms and procedures vary according to three main dimensions. One is that of internal versus external procedures, although both are interconnected. Secondly, there is a difference between voluntary and obligatory accountability although the line is not a sharp one, since a threat of compulsion may lead to voluntary action. Thirdly, there is a difference according to the type of penalty that might be involved (especially as between material and verbal penalties) and the severity of application. Liability Versus Answerability Christians (1989, 36) distinguishes between three main "levels of accountability, identified as those of liability, moral sanctions and answerability. The first relates to circumstances where formal and defined obligations exist, along with penalties for non-compliance. The second relates mainly to issues of moral or ethical concern. Answerability relates to many issues and circumstances where claims or complaints are made against media, calling for some explanation and debate although no liability to respond exists. Leaving aside the case of personal moral responsibility, there is a marked contrast between a model of accountability based on the idea of answerability and one based on liability. The former implies responsiveness to the views of all with a legitimate interest in what the media do, whether as individuals affected or on behalf of society. Answerability may not achieve redress or improvement, but it does reaffirm the norms appropriate to publication and is consistent with principles of freedom. The liability model mainly arises where harm is alleged and the media are blamed, rather than in relation to quality of content and service. It involves a relation of conflict with partners to the communication relationship. Its intended outcome is not explanation or reconciliation, but compensation or punishment and its application involves compulsion, which media are free to contest, but must ultimately submit to. The main differences between the two types of accountability, each with its own typical accounting procedures is summed up in the contrasts presented in Table 1. Table 1: Two Accountability Models Compared ANSWERABILITY LIABILITY Legal basis Compulsory Formal adjudication Adversarial relations Material penalties Reference to harm Social or moral basis Voluntary vs. vs. Dialogue and debate Cooperative relations Non-material penalties Reference to quality vs. vs. vs. vs. These are two opposed ideal types, with a range of intermediate possibilities. In any given case, there may be no freedom of choice, since a given type of accountability may not be available at all (for instance there is no formal liability for failing to follow certain ethical rules) or may be the only one available (as where legal regulations have to be enforced). However, in many cases where the liability path is pursued, there is an option of proceeding by another route. The position taken here is that the answerability model is generally the most suitable for dealing with the main issues of accountability that public communication gives rise to, even if it may be regarded as less effective and where formal procedures do exist, as is often the case with public broadcasting. The main reason for stating this preference is that answerability is most consistent with freedom to publish, since it involves no threats or punishments (and thus indirect censorship). It is also most consistent with a reasoned and principled defence of any given act of publication and is more likely to lead to voluntary acceptance of responsibility and also to improvement of performance. It is certainly much more appropriate to the search for the adoption of positive goals of serving the public good and likely to be more effective in this respect. It offers a way of solving some of the dilemmas of free publication, which can cause offence and harm to some, even when pursuing some public good, such as holding governments and powerful institutions to account. It is the best way of dealing with conflicted communication relations in the public life of society. The liability model depends at root on a model of media power and causal influence that has limited demonstra-bility and application. It has to be admitted that contemporary conditions of media systems are not very conducive to the applicability of the answerability model. Media are increasingly owned by large and remote corporations that are not inclined, even if they were able, to enter into meaningful dialogue with their audiences or those affected by their activities. They are often not at all connected with the national society or any local community. They obey such laws as apply, but are primarily governed by the conditions and rules of the market place. This large qualification does not, however, apply to public broadcasting, for reasons given below. This theoretical analysis can be concluded by reference to Figure 2, which summarizes much of the preceding argument in a single statement. Figure 2: A Summary of the Argument FREE MEDIA have RESPONSIBILITIES in the form of obligations that can be ASSIGNED, CONTRACTED OR SELF-CHOSEN for which they are held ACCOUNTABLE (legally, morally or socially) in the sense of either LIABILITY or ANSWERABILITY for harm caused for quality of performance Implications for Public Service Broadcasting Public service broadcasting is already the form of organisation of mass media that is most directly accountable to society in most of the possible meanings indicated. It was designed this way and this is a source of real benefits, especially a degree of freedom from constraints of the media market, and a responsiveness to the needs of society and of the audience that go beyond what the market often permits or encourages. Whatever the issue involved, the accountability it offers is both public and transparent in character and also enforceable and effective, because it is subject to operating conditions and can be legitimately regulated. However, the beneficial aspects of this situation are matched by some drawbacks, especially the limits placed on the freedom of communicators. These limits may be no greater than those applying to market-based media, but they will also tend in a different direction and have a different origin. The main issue that arises is whether public broadcasting is actually more accountable to the people as audience or body of citizens or the state or government. The more the latter, the less attractive the form of accountability in place and the more in fact that it resembles the working of the liability model outlined above, rather than the "answerability" model. The position of this article is that the latter model is preferable on grounds of freedom of communication and compatibility with the main virtues and benefits of free publication. These include increasingly the chances of discovering and disseminating truth, by whatever definition, as well as widening the opportunities for access to media and of diversity of communication for the audience. We also need to take account of the purposes of public service broadcasting. What are its objectives and justifications? What values is it meant to serve? Different priorities apply in different places, but there is some consensus that it should perform a number of positive informational and cultural tasks to an adequate level of quality and that it should also provide access to and reflection of society in diverse or proportional ways. There is a potential for formulating and applying criteria of performance in these and other respects and gaining compliance. There is an increasing tendency in this direction as public service broadcasting is relatively reduced in extent in the media system and called upon to perform relatively more tasks on behalf of the public interest. There is a risk in this of applying very close external supervision and eroding the limited freedom of broadcasters to carry out their work in a professional and creative way, neither of which is very compatible with the tendencies described. The purpose of the early part of this article was to underline the view that public service broadcasting is a valid and normal part of the contemporary media scene and does not have to be treated as an exceptional case, even if it is clearly different (for good reasons). It has also been argued that extensive obligations to society are also entailed in the publication activities of "private" media. Benefits to society that are expected from public broadcasting are also provided by these media, without their needing to be subjected to detailed regulation, close supervision and monitoring of every aspect of their activities. The greater potential for close monitoring of performance by public broadcasting is not a good enough reason for engaging in it. This applies to plans to conduct detailed "audits" of content and services. It is also worth underlining that "private" media are not free from responsibilities. 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