BSA Decisions Ngā Whakatau a te Mana Whanonga Kaipāho

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An appeal by Michael Hooker against this decision was dismissed in the High Court: AP SW 6/02  PDF1.09 MB

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Complaint
Stripsearch – series incorrectly classified as PGR – unsuitable for children – adult themes – breach of good taste – denigrated men – deceptive programming practice – broadcaster not mindful of effect on children

Findings
Standard G2 – did not exceed current norms of decency and good taste – no uphold

Standard G4 – participants not treated unjustly or unfairly – no uphold

Standard G6 – not relevant – no uphold

Standard G7 – no uphold

Standard G8 – warning that hybrid classification in final episode potentially a deceptive
                       programming practice – no uphold

Standard G12 – no uphold

Standard G13 – series did not discriminate against men – no uphold

This headnote does not form part of the decision.

Summary

[1] Stripsearch was a seven-part series broadcast on TV2 on Tuesday evenings at 8.00pm from 10 July 2001 until 21 August 2001. The series featured Billy Cross, an Australian impresario, and his efforts to put together at short notice a live male revue in New Zealand. He was shown travelling throughout the country auditioning applicants, from which he selected 12 performers for training, six of whom were chosen for the final performance.

[2] The first six episodes screened from 8.00pm to 8.30pm and were classified PGR. The final episode, which included extracts from the troupe’s performance at Sky City in Auckland, screened from 8.00pm until 9.30pm. The part of the final episode which screened after 8.30pm was classified AO.

[3] Jillian Davey on behalf of Preserving Communication Standards, Michael Hooker, and Penny Jones complained separately to Television New Zealand Ltd, the broadcaster, about aspects of the series.

[4] Mr Hooker and Ms Davey alleged the series breached standard G8 of the Television Code of Broadcasting Practice, because it was unsuitable for children and should have been classified AO. Mrs Jones also alleged a breach of standard G8, but only in relation to the first part of the final episode, broadcast on 21 August 2001. Ms Davey alleged breaches of various other broadcasting standards.

[5] TVNZ declined to uphold the complaints, maintaining that the series had been correctly classified, and accompanied by appropriate warnings.

[6] Dissatisfied with TVNZ’s decision, the complainants referred their complaints to the Broadcasting Standards Authority under s.8(1)(a) of the Broadcasting Act 1989.

For the reasons given, the Authority declines to uphold the complaints.

Decision

[7] The members of the Authority have viewed tapes of the first three episodes and the final episode of Stripsearch and have read the correspondence listed in the appendices. The Authority determines these complaints without a formal hearing.

The Programme

[8] Stripsearch was a seven-part series broadcast on TV2 on Tuesday evenings at 8.00pm from 10 July 2001 until 21 August 2001.

[9] The series featured Billy Cross, an Australian impresario, and his efforts to put together at short notice a live male revue in New Zealand. He was shown travelling throughout the country auditioning applicants, from which he selected 12 performers for training, six of whom were chosen for the final performance.

[10] The first six episodes screened from 8.00pm to 8.30pm and were classified PGR. The final episode, which included extracts from the troupe’s performance at Sky City in Auckland, screened from 8.00pm until 9.30pm. The part of the final episode which screened after 8.30pm was classified AO.

The Complainants

[11] Jillian Davey on behalf of Preserving Communication Standards, Michael Hooker, and Penny Jones complained separately to Television New Zealand Ltd, the broadcaster, about aspects of the series.

[12] Mr Hooker and Ms Davey alleged the entire series had been incorrectly classified and that it therefore breached standard G8 of the Television Code of Broadcasting Practice. Mrs Jones also alleged a breach of standard G8, but only in relation to the first part of the final episode, broadcast on 21 August 2001. In relation to the final episode, Mrs Jones’s complaint alleged a breach of standard G12.

[13] Ms Davey also alleged breaches of standards G2, G4, G6, G7 and G13.

The Standards

[14] In the preparation and presentation of programmes, those standards require broadcasters:

G2  To take into consideration currently accepted norms of decency and taste in language and behaviour, bearing in mind the context in which any language or behaviour occurs.

G4  To deal justly and fairly with any person taking part or referred to in any programme.

G6  To show balance, impartiality and fairness in dealing with political matters, current affairs and all questions of a controversial nature.

G7  To avoid the use of any deceptive programme practice in the presentation of programmes which takes advantage of the confidence viewers have in the integrity of broadcasting.

G8  To abide by the classification codes and their appropriate time bands as outlined in the agreed criteria for programme classifications.

G12  To be mindful of the effect any programme may have on children during their normally accepted viewing times.

G13  To avoid portraying people in a way which represents as inherently inferior, or is likely to encourage discrimination against, any section of the community on account of sex, race, age, disability, occupational status, sexual orientation or the holding of any religious, cultural or political belief. This requirement is not intended to prevent the broadcast of material which is:

i) factual, or

ii) the expression of genuinely-held opinion in a news or current affairs programme, or

iii) in the legitimate context of a humorous, satirical or dramatic work.

Mr Hooker’s Complaint

[15] Mr Hooker complained that, because stripping was "obviously an adult theme", the whole series should have been classified AO and should not have screened before 8.30pm.

Ms Davey’s Complaint

[16] In a letter of complaint about the episodes broadcast on 10, 17 and 24 July, Ms Davey said Preserving Communications Standards considered the concept of the programme was "obviously an Adults Only theme". Ms Davey said:

We think in addition that the selection process is grossly sexist and in reality, just degrading pornographic behaviour, certainly unfit for the time bank of 8pm!

[17] In a further letter of complaint about the episodes broadcast on 31 July, 7 August and 14 August, Ms Davey said the public expected the 7.30pm to 8.30pm timeband to contain material suitable for family viewing. She said representing "sordid, pornographic" behaviour as glamorous was in breach of standard G7. She also alleged a breach of standard G6, stating:

Another concern is that the grossly deviant and degrading nature of this concept, in what is controversial entertainment in society, is a breach of Code G6, in terms of gender roles being portrayed and promoted in a blatant manner.

Mrs Jones’s Complaint

[18] Mrs Jones complained about the final episode of the series, broadcast on 21 August. She noted that the programme was preceded by a warning that it was not suitable for children, and said:

That is good. However, by your admission, it is not suitable for children, therefore it should be on at the 8.30 adults only viewing time slot.

TVNZ Response to the Complainants under Standard G8

[19] TVNZ responded to the complainants that the subject matter of the series had been made clear from the beginning. It quoted the opening sequence, filmed on Australia’s Gold Coast, as follows:

Commentator:    Manpower Australia is the most successful male revue in the world
                         because of this man, Billy Cross.
Billy Cross:        This is where I did my first strip about twelve years ago, and now I own it.
Commentator:    And now he’s coming to New Zealand to begin a national strip-search for
                         Kiwi men.

[20] In TVNZ’s view, what the series was about was "encapsulated unambiguously in this passage".

[21] TVNZ said the filming of the men auditioning or rehearsing for the revue had been carefully framed so that there was no full frontal nudity. It said:

Some of the men were seen in skimpy attire, but in the [Complaints] Committee’s opinion no more skimpy than some of the swimming costumes worn by men on the country’s beaches during the summer months. The very brief shots involving nudity were discreetly filmed from behind.

[22] TVNZ said its Complaints Committee recognised that male revues were not to everyone’s liking. However, it said, TVNZ had an obligation to reflect the wide variety of tastes and interests in the New Zealand community. It said:

That this was to be a series about putting together a male revue was crystal clear from the start and nobody was compelled to watch it.

[23] In relation to the first six episodes, TVNZ quoted the definition of PGR in the Television Code of Broadcasting Practice, which reads:

Programmes containing material more suited to adult audiences but not necessarily unsuitable for child viewers when subject to the guidance of an adult.

[24] While acknowledging that the subject was "more suited to adult audiences," TVNZ said it did not believe the subject could not be seen by children under the guidance of an adult. PGR, it said, was "all about parental discretion", and while some parents might find the subject matter inherently unsuitable for children, others would not. TVNZ said children could "hardly be ignorant" of the existence of male reviews, with posters and newspaper advertising regularly accompanying their visits to towns and cities all over New Zealand.

[25] It noted that the PGR advice was reinforced by the appearance of the PGR symbol at the beginning of each episode, and after each commercial break, and by a carefully worded warning at the beginning of each episode which stated:

This programme, Stripsearch, contains coarse language and scenes that may not be suitable for young people. We recommend guidance from a parent or other adult, and advise discretion.

[26] In TVNZ’s view, nothing in the first six episodes covering the selection or auditioning of the dancers required a more restricted certificate than PGR. It said:

Male revues are part of life, widely publicised and seemingly accepted in the community as a legitimate form of entertainment, and the manner in which this series covered the search for and training of the performers did not seem to the committee to require AO restriction.

[27] TVNZ said it had recognised that the extended final episode, in which sequences from the actual performance at Sky City had been shown, had required an AO certificate. The first part of the final episode had been rated PGR, along with the warning, and the section containing the performance itself, which started after 8.30pm, had been classified AO. An extra warning had been displayed, carrying the AO symbol and the words:  This programme contains scenes that may offend some people. We advise discretion.

TVNZ’s Response to Ms Davey under Standards G2, G4, G6, G7 and G13

[30] In addition to the comments reported above, TVNZ responded to Ms Davey that it did not believe the subject matter of the series was degrading to those taking part. It said:

Each one of the would-be performers signed a consent form to appear in the television series, which they knew was to be shown nationwide. It was noted that Mr Cross in making his selection emphasised the professional nature of the performance, and rejected a number of applicants because in his opinion their audition performances were too sleazy.

[31] In assessing Ms Davey’s complaint under standard G2, TVNZ said it was required to consider the context in which the series was broadcast. Noting that the series carried a PGR certificate and that the PGR symbol was shown at the beginning of each programme and after each commercial break, TVNZ declined to uphold a breach of standard G2. It said:

… given the context of a programme which was clearly sign-posted from the very beginning as being about a search for performers in an all-male revue, it was difficult to conclude that the content would then have exceeded "currently accepted norms" of decency and taste – or indeed would have strayed beyond the expectations of the audience.

[32] In relation to standard G4, TVNZ said it could not understand why Ms Davey had cited the standard. All participants had consented to appear on the programme, it said, and it was not possible to conclude that any had been unjustly or unfairly treated.

[33] Assessing Ms Davey’s complaint under standard G13, TVNZ noted that the complainant had accused the selection process of being sexist. It said:

That selection process is not in the hands of the broadcast; it was organised by Mr Cross and his team. Whether or not the process is inherently sexist, male revues exist and a series which shows how one is assembled is a legitimate and interesting topic for a television series. It is not valid to suggest that the men were portrayed as being "inherently inferior" or that discrimination against them was encouraged. The series tended to put the men on a pedestal and stressed the need for professionalism in the performances they were undertaking.

[34] TVNZ said it could not understand the relevance of standard G7 to Ms Davey’s complaint, there having been no "deceptive programme practice" involved. Similarly, TVNZ said it could not understand the relevance of standard G6, unless the complainant was contending that any programme dealing exclusively with men must have a "balancing" section devoted exclusively to women. It said:

That we suggest, would be absurd. If TVNZ were to present a history of the famous follies in Paris, would you similarly insist on a male revue to provide the "balance"?

TVNZ’s Response to Mrs Jones under G12

[35] In relation to Mrs Jones’s complaint that the final episode in the series breached standard G12, TVNZ said it was the opinion of its Complaints Committee that by attaching at 8pm a PGR certificate and a warning, and by later in the programme broadcasting a second warning in association with an AO certificate, TV2 had demonstrated that it was mindful of the effect the programme may have had on children. It declined to uphold the complaint that standard G12 had been breached.

Mr Hooker’s Referral to the Authority

[36] In his referral to the Authority, Mr Hooker said:

I believe the veracity of my complaint can easily be established by asking two simple questions.

        1) Is stripping to sexually arouse an adult theme?
        2) Should programmes which contain adult themes be rated AO?
…
The fact that TVNZ is unwilling to concede such indisputable points is indicative of a fundamental unwillingness to abide by the television programme classifications as outlined in the Codes of Broadcasting Practice.

[37] In his view, Stripsearch did not merely contain adult themes but was "entirely devoted to an adult theme". Referring to TVNZ’s comments about the degree of nudity shown, Mr Hooker said "stripping to sexually titillate" was an adult theme, even if no nudity was shown.

[38] Mr Hooker said he agreed that TVNZ had an obligation to reflect the wide variety of tastes and interests in the New Zealand community, so long as it fulfilled this obligation in accordance with the programme standards set out in the Television Code of Broadcasting Practice.

[39] Mr Hooker said TVNZ’s comment, that it had been "crystal clear" from the beginning that the series was about putting together a male revue, only reinforced his contention that the series was entirely devoted to an adult theme.

[40] In relation to TVNZ’s comment that nobody was compelled to watch the series, Mr Hooker said he could not understand how this was relevant to determining the classification of a programme.

[41] Mr Hooker said TVNZ had incorrectly assessed his complaint that the series breached standard G8 when it referred to the definition for PGR material. He suggested the complaint should have been assessed under the definition of AO material, which reads:

Programmes containing adult themes or those which, because of the way the material is handled, would be unsuitable for persons under 18 years.

[42] In relation to TVNZ’s comments that stripping was subject matter children could view under the guidance of an adult, Mr Hooker said:

I consider that this raises serious questions as to the suitability of the committee members to exercise sound judgement in the protection of children from unsuitable content.

Ms Davey’s Referral to the Authority

[43] In her referral to the Authority, Ms Davey maintained that the "unsavoury behaviour" shown in the series meant it should have been classified AO. She said the Preserving Communications Standards group felt the broadcaster was exploiting the PGR rating. Ms Davey maintained that the series was denigratory. She also maintained that standards G6 and G7 were relevant. She said representing "sordid behaviour" as "glamorous and attractive" was a deceptive programming practice. She said the group believed the broadcaster "has never screened or intends to screen a similar all-female revue", because it would be seen as "too degrading, offensive and controversial".

Mrs Jones’s Referral to the Authority

[44] In her referral, Mrs Jones rejected TVNZ’s explanation that the subject matter of the series was made clear at the beginning, and that nobody was compelled to watch it. She said TVNZ’s comments assumed every viewer watched the series from the beginning, and took on board that information. She said:

This is a surprising show of naivete about viewing habits! The reality is that many people sit down, turn the TV on and start watching at any moment of the day or evening. And some of these people are children. Surely the test should be "If a child were to turn on the TV now, what would be the effect?" Certainly one little clip out of context might give the wrong impression about a programme, but children are impressionable!

[45] In Mrs Jones’s view, TVNZ’s comment that a lot of subjects on television were not to everyone’s liking was an "attempt to run for cover" and no defence.

[46] In relation to TVNZ’s argument that it was obliged to reflect the wide tastes and interests found in New Zealand, Mrs Jones said:

But we are talking about something that borders on prurience. This is not men in togs at the beach, it’s about men preparing to strip so women can oogle at them in a voyeuristic way.

Again – children should be protected from this during normal viewing hours. Stripping for sexual titillation is not something that children should be modelling, so why show a programme based on this during their viewing time?

[47] In relation to the AO warning prior to the 8.30pm segment of the final programme, Mrs Jones said it was more difficult to switch off part way through a programme, once drawn in to an episode. She said standard G8 referred to "programme classifications", not multiple classifications for a given programme.

[48] Mrs Jones concluded:

TVNZ has tried to draw viewers in before 8.30pm to a programme which is prurient, and unsuitable for children. By a device of different grades of warnings they have straddled the 8.30pm time zone, and this way hoped to capture more viewers. Some of those viewers were children.

TVNZ’s Responses to the Authority

[49] TVNZ disagreed with Mr Hooker’s comment that it should have assessed his complaint by looking at the definition of the AO classification. It said its role was to judge whether the programme had been appropriately classified, and in its view nothing in the [first six] episodes required a more restricted certificate than PGR.

[50] In response to Mr Hooker’s view that male revues were an "adult theme", TVNZ suggested what some regard as adult themes were regularly included in PGR material. It said:

That you would not let a child go to a male revue does not mean that the child should be denied all knowledge that such events exits. Surely this a matter where parental discretion should apply?

[51] TVNZ noted that the material in the final episode, showing extracts from an actual performance, had been given an AO certificate.

[52] In response to Ms Davey’s comment that "the broadcaster has never screened or intends to screen a similar all female revue", TVNZ said:

With respect to Ms Davey, it is not too many years ago that shows involving women in provocative poses and in various states of undress were relatively common on television. Their presence on television reflected the reality of the times when such shows – often in cabaret form, in swimsuit parades, or in beauty contests – received a great deal of publicity and were eagerly attended by live audiences. Now times have changed and we are going through a period when the community is showing particular interest in male revues. Television is reflecting that reality.

[53] In response to Mrs Jones’s referral, TVNZ maintained that the material in the first part of the final episode was PGR material more suited to an adult audience. TVNZ suggested the material:

… was of a nature where adult discretion was appropriate so that those among the audience who felt the subject matter was unsuitable for their juvenile charges could make a decision not to watch.

[54] TVNZ disagreed with Mrs Jones’s suggestion that the warning amounted to an admission that the programme was not suitable for children. It noted that over recent years TVNZ and other broadcasters had increased the number of warnings used, and had made them more specific, so that adults could be assisted to make an informed decision about whether they or their children should watch a given programme. It noted that the final episode started in PGR time, with a warning indicating why TVNZ was recommending parental guidance.

Mr Hooker’s Final Comment

[55] Mr Hooker referred the Authority to Decision No: 1999-026 in which the Authority upheld a complaint about an episode of Dharma and Greg under standard G8 because the entire focus of the programme complained about was sex. Mr Hooker asserted that "the entire focus of Stripsearch was sex" and that "explicit sexual activity pervaded Stripsearch".

[56] From his reading of the definition of AO material, Mr Hooker said he believed that any programme which had an adult theme as a component should be classified AO. He also asked the Authority to consider his complaint under standards G2 and G12.

Ms Davey’s Final Comment

[57] In her final comment to the Authority, Ms Davey asked the Authority to take into consideration the "specific entertainment being promoted in this prolonged programme series". In relation to standard G6, she suggested TVNZ had shown partiality by promoting male stripping.

Mrs Jones’s Final Comment

[58] Mrs Jones reiterated her earlier comments, and added:

Is this the beginning of splitting programmes where the beginning might be debatably ok for children, and the second half of the programme having the adult content? If this is the case, do they bring into their consideration that the children have got hooked into the programme and many parents will find it hard to pull them away. It’s human nature to want to know what happens in the end.

TVNZ’s Response to Mr Hooker’s Final Comment

[59] TVNZ responded to Mr Hooker’s final comment by explaining that the episode of Dharma and Greg had been upheld as a breach of standard G8 because it involved specific reference to sexual acts occurring outdoors and in a public place. This was "in no way comparable" to the sequences in Stripsearch, TVNZ said. TVNZ also disputed Mr Hooker’s assertion that the entire focus of Stripsearch was sex, and that it was pervaded by "explicit sexual activity".

The Authority’s Determination

[60] Jillian Davey on behalf of Preserving Communication Standards, Michael Hooker, and Penny Jones complained separately to TVNZ about aspects of the seven-part series Stripsearch. The Authority deals with the complaints together.

[61] The first six episodes of Stripsearch screened from 8.00pm to 8.30pm and were classified PGR. The final episode, which included extracts from the troupe’s performance at Sky City in Auckland, screened from 8.00pm until 9.30pm. The part of the final episode which screened after 8.30pm was classified AO.

[62] The first task for the Authority is to determine the complaints under standard G8. That standard requires broadcasters to abide by the classification codes and their appropriate time bands. Mr Hooker and Ms Davey complained that the entire series should have been classified AO and should not have screened before 8.30pm. Mrs Jones’s complaint was limited to the final episode of the series, the whole of which, she said, should have been screened after 8.30pm.

[63] In relation to the first six episodes which were rated PGR, the Authority considers the broadcaster has only narrowly avoided breaching standard G8. The Authority doubts that a series such as Stripsearch is one where parents could realistically be expected to sit down with, and guide, their children. It accepts, however, that the first six episodes would not necessarily have been unsuitable for younger viewers under the guidance of an adult. Accordingly, the Authority declines to uphold the aspect of the complaints that the broadcaster breached standard G8 when it classified the first six episodes PGR.

[64] With regard to the final episode of the series, the Authority begins by noting its concern with a practice on which it has not previously been asked to rule. In contrast to, for example, the series Big Brother, which was sometimes shown during PGR time and sometimes during AO time depending on its content, the final episode of Stripsearch was a single programme with a "hybrid" classification. The Authority believes that it is understandable that viewers would want to see a programme through to the end. In the Authority’s view, the practice of rating the first part of a programme PGR and the second part of the programme AO may entice children and young people to watch the whole of the programme, even though the broadcaster acknowledges that part of it is inappropriate for them. On this occasion, the Authority declines to uphold the aspect of the complaints that the final episode was incorrectly classified. However, it warns broadcasters that the use of the classification system to split one programme into separate classifications was not envisaged when the classification system was devised. Such a device could entice younger people to watch AO programmes which are inappropriate. This practice could well lead the Authority to uphold future complaints of a similar nature under standard G7. That standard requires broadcasters:

G7 To avoid the use of any deceptive programme practice in the presentation of programmes which takes advantage of the confidence viewers have in the integrity of broadcasting.

[65] The Authority now considers the aspects of Ms Davey’s complaint alleging breaches of standards G2, G4, G6, G7 and G13.

[66] When it considers complaints alleging a breach of standard G2, the Authority is required to take into account the context in which the alleged breach occurred. On this occasion, the relevant contextual factors include the time of broadcast, the warnings, and the PGR and AO classifications. In the Authority’s view, the series did not exceed current norms of decency and good taste, and it declines to uphold a breach of standard G2. In reaching this decision, the Authority records that to find a breach of good taste would be to interpret the Broadcasting Act 1989 in a manner which places too great a limit on the broadcaster’s statutory right to freedom of expression in s.14 of the New Zealand Bill of Rights Act 1990. The Authority prefers to adopt an interpretation of the standard which is consistent with the Bill of Rights.

[67] In relation to standard G4, the Authority concurs with the broadcaster that there was nothing in the series to indicate that any of the participants had been treated unjustly or unfairly, all having freely consented to appear on the programme. The Authority declines to uphold a breach of standard G4.

[68] Similarly, the Authority agrees with TVNZ that standard G6 is not relevant. The series was not dealing with political matters, current affairs or questions of a controversial nature as contemplated by the standard. In any event, it was not necessary for the broadcaster to include an all-female revue in order for the series to be balanced.

[69] The essence of Ms Davey’s complaint under standard G7 was that "sordid, pornographic" behaviour should not be presented as "glamorous". That is not a "deceptive programming practice" of the kind envisaged by standard G7, and the Authority declines to uphold this aspect of the complaint.

[70] However, as the Authority has already noted in its discussion under standard G8 above, it might in future be mindful to uphold a breach of standard G7 if broadcasters split one programme into separate classifications. In that regard, the Authority draws broadcasters’ attention to Standard 8 in the new Free-to-Air Television Code of Broadcasting Practice. The Authority approved the Code on 13 August 2001, and it will come into effect on 1 January 2002. Standard 8 reads:

Broadcasters are responsible for ensuring that programme information and structure does not deceive or disadvantage the viewer.

[71] The Authority declines to uphold a breach of standard G13. In its view, the series did not portray men as inherently inferior, or in such a manner as to encourage discrimination against them.

[72] Finally, the Authority considers the aspect of Mrs Jones’s complaint that the final episode breached standard G12. That standard requires broadcasters to be mindful of the effect any programme may have on children during their normally accepted viewing times. Again, the Authority records its concern with and disapproval of the use of a "hybrid" classification in the final episode. It warns broadcasters that such a practice has the potential to breach standard G12. On this occasion, however, the Authority notes that the part of the programme which screened during children’s normally accepted viewing times between 8.00pm and 8.30pm was correctly classified PGR and was accompanied by a warning. It notes that when the programme changed to AO at 8.30pm, there was a second warning. Accordingly, it declines to uphold the aspect of Mrs Jones’s complaint that the final episode breached standard G12.

For the reasons given above, the Authority declines to uphold the complaints.

Signed for and on behalf of the Authority

Peter Cartwright
Chair
17 December 2001

Appendix I

The following correspondence was received and considered by the Authority when it determined this complaint:

1. Michael Hooker’s Formal Complaint to Television New Zealand Ltd – 20 August 2001
2. TVNZ’s Response to the Formal Complaint – 29 August 2001
3. Mr Hooker’s Referral to the Broadcasting Standards Authority – 1 September 2001
4. TVNZ’s Response to the Authority – 10 September 2001
5. Mr Hooker’s Final Comment – 29 September 2001
6. TVNZ’s Response to the Final Comment – 8 October 2001
7. Mr Hooker’s Further Correspondence – 14 October 2001

Appendix II

The following correspondence was received and considered by the Authority when it determined this complaint:

1. Jillian Davey’s Formal Complaints to Television New Zealand Ltd –
    26 July 2001 and 16 August 2001
2. TVNZ’s Responses to the Formal Complaints – 23 August 2001
3. Ms Davey’s Referral to the Broadcasting Standards Authority – 4 September 2001
4. TVNZ’s Response to the Authority – 11 September 2001
5. Ms Davey’s Final Comment – 18 September 2001

Appendix III

The following correspondence was received and considered by the Authority when it determined this complaint:

1. Penny Jones’s Formal Complaint to Television New Zealand Ltd – 23 August 2001
2. TVNZ’s Response to the Formal Complaint – 10 September 2001
3. Mrs Jones’s Referral to the Broadcasting Standards Authority – 19 September 2001
4. TVNZ’s Response to the Authority – 3 October 2001
5. Mrs Jones’s Final Comment – 22 October 2001