The document is being submitted to Sir David Calcutt, who has been asked by the National Heritage ministry to see whether press self-regulation is working effectively or needs to be tightened.
'There is unequivocal evidence that self-regulation is now working,' the submission says. 'The PCC have enforced a swift and effective shake-up of newspapers up and down the country . . . What the Code of Practice has done is clear away much of the fog left by the old Press Council.'
Noting that in the most publicised of this year's scandals there was no complaint from any of the parties directly involved, the document says that the behaviour of the press seemed to upset the politicians more than the public. 'In each (case) it could be argued there was a tenable case for publication. It is no function of the press to protect public figures from the consequences of their own follies.'
This is a clear reference to David Mellor, the former Secretary of State for National Heritage, whose affair with an actress contributed to his resignation, and to the Duchess of York, photographed with her financial adviser. However, the argument seems to conflict with the statement made by the commission's chairman, Lord McGregor, after the publication of revelations about the Prince of Wales's marriage, when he accused journalists of 'dabbling their fingers in the stuff of other people's souls'.
Many newspaper editors are quoted in the submission as endorsing the commission, headed by Kelvin MacKenzie, of the Sun, which has had nine complaints against it upheld - three times as many as any other daily paper. 'In our view the Code of Practice has been an outstanding success,' Mr MacKenzie says. 'The PCC has earned far greater respect than its predecessor, the Press Council.'
Other editors come out strongly against a privacy Bill or other statutory controls. The commission itself declares that any such legislation 'would be incompatible with the British democratic tradition and would put freedom of expression at risk'.
In its first 18 months, the commission received 2,069 communications from the public and upheld 51 complaints. Sir David is due to make recommendations on its future in January.