Delivery as addressed mail is the best distribution model
Deputy-Ombudsman's position on distribution of parish magazines
In the view of Deputy-Ombudsman Jukka Lindstedt, the best of the various alternative distribution models for church magazines seems to be to have them delivered as addressed items to members of the congregation. It is the one that best takes into consideration the client perspective that belongs to good administration.
Church obligated, on its own initiative, by the Administrative Procedure Act
The Evangelical-Lutheran Church of Finland is bound by legislation that was enacted on the Church?s own initiative. Therefore also distribution of parish magazines can be appraised from the perspective of what demands the Administrative Procedure Act that the Church has embraced makes with regard to the Church's activities.
In the view of the Deputy-Ombudsman, a person becomes a client of administration in the meaning of the Administrative Procedure Act at the latest when he or she turns to a congregation in a matter to do with distribution of a parish magazine.
Principles of good administration, which include the principle of service and taking the client's point of view into consideration, are enshrined in the Administrative Procedure Act. Applied to distribution of parish magazines, this means that a congregation should ensure, as simply and flexibly as possible, the client's opportunity to make his or her choice: to have the magazine delivered home or not.
Complaints and different distribution channels
The Deputy-Ombudsman has now been investigating eight new complaints concerning delivery as unaddressed items of parish magazines. There have been no complaints from parishes where the magazines have been distributed as addressed mail. About half of all parish magazines are distributed as addressed mail, including the one with the largest circulation, Kirkko ja kaupunki ("Church and City"), which is published by the Helsinki group of congregations.
The other half of parish magazines are distributed as unaddressed items together with advertising and free sheets. The complainants generally would not have wanted to receive a parish magazine, but did welcome advertising or free sheets. However, the only way they could stop parish magazines being delivered to them was to prohibit delivery of all advertising or free sheets.
On the other hand, one complainant would have liked to receive the parish magazine, but could not do so, having prohibited all delivery of advertising or free sheets.
Under the terms of contract, a parish magazine may not be delivered to those households that have prohibited advertising or free sheets. Thus the operational practices followed in this field do not seem to offer a satisfactory solution to the problems that have manifested themselves.
Position adopted by the Constitutional Law Committee in 2007
The Eduskunta's Constitutional Law Committee adopted the position in a 2007 report that from the perspective of freedom of expression and religion there is no impediment to parish magazines being distributed also to households that do not want them. The Deputy-Ombudsman notes that on this point he cannot deviate from the position of the Committee.
Additional information will be provided by Secretary General Jussi Pajuoja, tel. +358 (0)9 432 3385.