PRCA Statement on Public Affairs Board Complaint

In October 2023, the PRCA completed an independent investigation into a complaint against Deryn Consulting Ltd, made under the Public Affairs Code. This looked into tweets posted by Deryn relating to the sentencing of a paedophile in Welsh politics.

The independent adjudicator concluded that the complaint did not warrant further action because it fell outside the Code’s scope.

Concerns raised by Deryn regarding the investigation process itself prompted an independent review commissioned by the PRCA’s Management Board. This review validated Deryn’s concerns and recommended improvements to our processes, the majority of which were already underway.

Since 1 January 2024 all complaints of a breach of the PRCA’s Codes of Conduct are considered by the PRCA’s new Standards Committee, which has a majority of independent members who are also responsible for setting the standards.

The Committee has introduced a completely new procedure for handling complaints under both the Public Affairs Code and the PRCA Code of Conduct. This came into effect on 1 July 2024 - the same time as a new PRCA Code of Conduct.

The Standards Committee, in conjunction with the Public Affairs Board, is now looking to review the Public Affairs Code, which will be subject to a full consultation.

The remaining actions of the independent review were put into place following a PRCA Management Board meeting in April 2024.

We are publishing a Q&A related to the independent review below for transparency. The PRCA is satisfied that all necessary steps are in place to ensure this situation cannot happen again.

The PRCA wishes to apologise unreservedly to Deryn for the distress and inconvenience caused. Misogyny, bullying and harassment have no place in our or any other industry and our focus must be on empowering women to call out bad behaviour and supporting them when they do.

Independent review findings Q&A:

1. Did the PRCA Public Affairs Board in place at the time follow the correct process (given the previous wording of the Code) in referring the initial complaint to the independent adjudicator?

The review identified some missed opportunities to dismiss the complaint before it was referred to the independent arbitrator (who did then dismiss it because there was not a prima facie case).

2. Is the Code and its procedures vulnerable to abuse from third parties and how can the risk of this be reduced?

The procedures for handling a complaint under the Public Affairs Code and the PRCA Code of Conduct have been completely revised since the investigation into the Deryn complaint. We are satisfied that the new procedures are robust enough to root out complaints that are not made in good faith.

3. In light of this review, what improvements should be made to the Public Affairs Code of Conduct and the procedure for alleged breaches in future?

The procedure for handling complaints under the Public Affairs Code and PRCA Code of Conduct has completely changed since the creation of the Standards Board. A copy of the new procedure can be found here: PRCA Complaints Procedure_0.pdf. A review of the Public Affairs Code itself, including a full consultation, will be underway later this year.

4. Is there evidence of conscious or unconscious misogyny here and, if so, by whom and what steps can be taken to eradicate this?

The review found no evidence of intentional conscious misogyny. It highlighted concerns around unconscious misogyny related to the initial complaint. The PRCA Management Board is determined to take a lead by providing relevant training in this area to all members of PRCA Boards and PRCA members of staff.

5. Why hasn’t the PRCA published the full independent review?

The PRCA has committed to implementing all the remaining recommendations of the review which have not already been addressed by the creation of the Standards Committee. The report itself names both staff members and volunteers who would be identifiable even if details were redacted. We are also bound by the confidentiality requirements inherent in our processes.