Fairfax is clear of breaching the audit rules – now change those rules

Hi Tim.

You’re 100% right that credibility is the key issue here.

When the rules were re-drafted in 2006, subscriber copies were basically of two sorts. The first was individual copies to a person’s home address. The second was copies to an office – not a specific person, but to a specific address.

The distribution of printed newspapers (and magazines) has changed dramatically since then as publishers rightly strive to get their product in as many consumer’s hands as possible. One of these new distribution channels for subscriptions was “campus copies”. In essence, many, many students paid for an upfront annual subscription. These copies were heavily discounted, and remembering my uni days I wish I had have had that same opportunity back then.

The difference is that the “campus copies” are not distributed to a specific address. It is up to the student to show their subscription card and pick it up from the common distribution point. Of course, not every student subscriber will pick up their copy every day (and they tend to pick it up last thing in the day) which overstates the number. Conversely, I bet many copies are picked up without a student who is not a paying subscriber. I think we all agree that this subscriber number therefore is a very rubbery cohort of the actual number of copies that end up in a student’s hands.

Traditionally we have assumed that subscriber copies were always delivered. That is, the newsagent’s throwing arm was accurate enough to hit the front lawn every time from the car. (By the way, did you know it is illegal to throw anything from a moving car!). While we can’t guarantee 100% delivery every day, it is a perfectly acceptable assumption that a subscription copy is delivered. The same goes for office subscriptions – in fact the number of eyeballs will exceed the number of office copies in most instances.

Where the assumption collapses is with “campus copies” and the like, where there is a bulk delivery, and not a specific delivery. Clearly, NO-ONE is happy with this defect in the rules – hence the urgent review being undertaken.

Regarding the instance which you videoed at Sydney Uni, what I am aware of is that if the number of copies delivered to the campus exceeded the number of subscriptions, then the audit would only allow the subscription number through. (Conversely, if the deliveries were less than the subscriptions, the delivery number would be used for the audit). Yep, either way the number was too high by what we all understand a paid copy to be. Yep, the number was within the existing (but soon to be amended) rules. No, not all those pallets counted towards the audit. No, those extra copies would never have passed audit if they exceeded the number of subscriptions.

The thing is, this is clearly a valid mode of distribution and we can’t allow a rule to define what can and cannot be used for distribution models. It is also clearly quite different to traditional subscription copies, therefore they will need to be broken out and transparently separately reported as part of the rule revision.

And finally, the 2006 rules revision – which created the various ‘buckets’ for sales – also presented the opportunity for publishers to aggregate the ‘buckets’ to come up with a “winning number”. It was agreed at the time that having multiple #1s in the market at the same time was not a good look, therefore all PR was to be based on Average Nett Paid Sales and not some other construct which could confuse the marketplace. Of course subscribers and agencies have full data and can construct the quantum than most closely meets their clients needs. I believe this principle still applies.

Cheers … and on with the rules rewrite!