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More information on Media within Kennedy Van der Laan

RVD Extends Media Code: Linking to Private Photographs of Members of Royal Family Is Unlawful

E-mail from the RVD
It appeared that the Dutch Government Information Service (Rijksvoorlichtingsdienst or "RVD") sent a rather special e-mail to journalists who report on the Dutch royal family. In an attempt to extend the Media Code, journalists are warned that it is prohibited to link to unauthorized private photographs of members of the royal family. Below is an extract of the e-mail from the Ministry of General Affairs (which incorporates the RVD):

As already known, members of the Royal House, just like any other family, have the right to feel free and remain unnoticed in private circumstances. There is only a legal justification to infringe their personal privacy by publishing private photographs when the publication of the photographs contributes to a public debate of general interest.

Posting a link to a private photograph of a member of the Royal House is equal to the publication of that photograph to the extent that when the photograph concerned is not a contribution to a public debate of general interest the posting of the links is also an unlawful act.

It appears from case law, inter alia, that an underlying document that can be retrieved by one act (namely clicking/double clicking on the link) is deemed to be connected to the link in such a manner that by posting the link the document has become, in a way, a part of the document in which the link is posted. This way, by posting the link the underlying document is also distributed. …

Contents of E-Mail Incorrect; Linking Is Only Unlawful in Exceptional Cases
Apparently, the RVD wanted to create some clarity, but the point is that this is not in line with case law, as the RVD wants the journalists to believe. The e-mail of the RVD seems to quote from a criminal case from 2007 (in Dutch). This case concerned links to fundamentalist Islamic texts in which violent actions were incited against the public authorities. According to the court, this was criminal incitement. It seems that the RVD wrongly distils a general rule from this criminal case that linking to a document is equal to publishing that document. This judgment does not have this general purport. This is a criminal case in which the exact description of the crime and the circumstances are decisive. This case did not at all concern the civil-law question of whether linking to unlawful content itself is also unlawful.

Incidentally, in exceptional cases, linking to unlawful content may be unlawful. The example that is usually relied on is a judgment from 2002 in which the court ruled that a number of links on the Indymedia website were unlawful. The links led to articles in which it was described how the railroad traffic of Deutsche Bahn can be sabotaged. In the article it was described, amongst other things, how a hook claw can be made with which the electric catenaries of the railroad network can be destroyed. In an earlier court action the articles had already been declared unlawful.

The Indymedia case was an exceptional case. First of all, this concerned a kind of terrorism handbook, which, according to the court, could present a danger to persons and goods. Secondly, the court had declared the texts to be unlawful already before. Thirdly, the link was not included in a journalistic production, but in reactions on the Indymedia forum. These were the circumstances which had the court declare that the links to the article were unlawful. Therefore, this judgment is the exception to the rule.

Copyright-law case law also contradicts the claim of the RVD. According to this case law, the “regular” (not embedded) linking to content is not a disclosure of this content.

Words of Warning
The argument of the RVD that the publication of a private photograph of a royal highness is automatically unlawful if it does not contribute to a public debate of general interest, leaves much room for negotiation. But the claim that linking to a private photograph of one of the members of the House of Orange is unlawful, is even more remarkable. Nevertheless, the RVD concludes with the following words of warning:

I advise you to take the above into account in the future and when posting a link to private photographs of members of the Royal House that are located elsewhere on the Internet, just like when publishing such photographs, to first consider whether a contribution is made to a public debate of general interest.

It is now common knowledge that the RVD takes measures against any media that do not obey its rules. For instance, such media will not be allowed to attend official photo moments with the Royal Family anymore. And that is were the shoe pinches. The Royal Family has, of course, the right to privacy. And it is also completely understandable that, for instance, Willem Alexander and Maxima keep a sharp eye on their children leading a normal life as far as possible, without too much media attention. But it is remarkable that the Queen, as a member of the government, and the RVD, which falls under the Ministry of General Affairs, make their own rules. Rules that are stricter than the rules applying to their own citizens. If the media do not stick to the rules created by the RVD, their free access to information will be restricted as a “punishment”.

The question is whether the RVD is doing the Royal Family a favor with this kind of mails.

Here you can find my comments (in Dutch) in the RTL Boulevard television program.

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Jens van den Brink

Tel: +31 20 5506 843
E-mail: jens.van.den.brink@kvdl.nl

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