Development of Right to Privacy in UK Law

Development of Right to Privacy in UK Law ‘Critically evaluate how privacy is protected and what extent a right to privacy has been developed in English law.’ The law of privacy remains a fast moving and chaotic area of law, where newspapers and Courts have something new to say almost on a weekly basis[1]. However, at present there is no single comprehensive tort of privacy in statute law in the United Kingdom, the House of Lords confirmed this view in the Wainwright v Home Office[2]. Yet, even with no protected rights to privacy enshrined in domestic law, people have now never been in a better situation to protect their privacy. This essay will therefore attempt to evaluate the evidential paradox England has in relation to how individuals are protected. In order to answer the initial question of how privacy is protected, this essay will firstly address the significance of the pre-existing torts and implementation of Human Rights Act (HRA) being the â€Å"catalyst for legal change†[3]. Whilst in conjunction examining the relevant case laws which have been at the forefront of these claims. Secondly, in order to answer the latter part of the question this analysis will explore the allegations of an infringement of personal privacy that have emerged from the Campbell ruling. Lastly, it will then conclude by summarising the points made within this evaluation and a proposal into the future of the law. First off, in order to consider the extent to which privacy is protected it is important to examine the values that underpin this somewhat vague concept. Privacy by its nature consists of many differing paradigms, which vary wildly between context and environment; it is therefore difficult to rely on a single interpretation. This was emphasised by the Calcutt Committee in 1990 with the Report of the Committee on Privacy and Related Matters who concluded that they couldn’t find â€Å"a wholly satisfactory statutory definition of privacy†[4]. The climate of uncertainty can be related to the fact that even within the 21st century; the legal definition of privacy remains in its infancy, still deriving from the 19th century Judge Cooley â€Å"the right to be let alone†[5]. What then makes Privacy law such a problematic area for journalists is the fact that journalists work to publish what is considered in the public interest, which are both eager to sell and hungry to devour any salacious information about celebrities. Nevertheless what newspaper proprietors and the public want are not considered a legitimate test[6]. Thus, creating a tense relationship between interests of privacy and interest of freedom of expression. Because there is no privacy law journalists must work within other laws which provide privacy. For the purpose of a chronological analysis into English law, the starting point concerning the debate between privacy and freedom of expression for journalists involves the era pre HRA. A pivotal case which emerged from this period was the Kaye V Robertson[7] when the actor Gordon Kaye was ‘interviewed’ and photographed by a journalist whilst he was heavily sedated and recovering from brain surgery. He was granted a legal case under malicious falsehood, even though Lord Justice Bingham acknowledged it was a â€Å"monstrous invasion of privacy†[8]. The laws of trespass and nuisance provided a slight protection against physical intrusions by the media when Kaye obtained a partial injunction; however, it evidently failed to provide protection against the publication of private facts when they have been obtained by other means. So prior to the enactment of HRA, the potential remedies available to an individual to media intrusions were severely limited and the breach of confidence was often the most useful remedy for protecting information. Recognising the problematic void within the law the British judiciary attempted to bridge the gap by adapting a pre-existing tort into a general right to privacy. Therefore breach of confidence has undergone some significant developments, extending the types of confidential information into a relevant stepping stone to decide privacy cases. Traditionally, this tort was developed in 19th century in common law to protect secrets to Albert v Strange[9], not specifically designed to protect privacy. However, Later cases including Coco v A. N. ClarkCoco v A. N. Clark Coco v A. N. Clark Coco v A. N. Clark [10] and the Spy catcher case[11] could be argued to have narrowed the area of the law down which lay the parameters for the Megarry test. This test extended privacy to where there is no relationship between the parties and that the information will likely to have damaging consequences if published. Taking the Francome v Mirror Group Newspapers[12] as an example; the defendant was able to claim damages when a journalist acquired private information by tapping the telephone of John Francome. So whilst breach of confidence no longer requires a pre-existing relationship. It can now make it entirely possible for it to become a move towards protecting privacy, as opposed to primarily protecting Confidence. Which was further emphasised in Douglas v. Hello!, Ltd[13] where actors Michael Douglas and Catherine Zeta-Jones won an injunction against a tabloid magazine for publishing covertly taking photos of their wedding when the rights had already been sold to its rival. Dispending that the requirement of a relationship of confidence as Hello! were not never a party to the relationship. The crucial stage of privacy law lies with the implementation of the HRA which came into effect in October, 2000. It became clear early on that this development would be responsible for developing a legal concept of privacy beyond the law of confidentiality[14]. As whilst Breach of confidence faces us with a simple balancing exercise between how information is collected, when we turn to the HRA, we’re faced with something more complex. As in accordance with Section.1 of the HRA it contains the rights and fundamental freedoms set out in Article.8 everyone has the right to respect for his private and family life[15]. Yet, Article.10 asserts everyone has the right to freedom of expression[16] and these rights set out in both Articles are both qualified and neither article has precedence over the other blurring the line between what can be reported on. The leading case to come before the English courts post HRA was the Campbell v Mirror Group Newspapers Ltd[17]. This case was concerned with two articles that were published by the Mirror on Naomi Campbell’s drug addiction and treatment. The news articles were accompanied with a covertly obtained photograph of the claimant leaving Narcotics Anonymous. The Mirror Group asserted that they should not be liable as the information published was in the public interest, since Campbell had deceived the public in regards to her drug addiction. What remains pivotal about this case is that the majority did rely upon the HRA in its decision. Furthermore, the discussions surrounding confidence laid the foundation for a new tort, which has come to be known by the name given to it by Lord Nicholls: â€Å"misuse of private information†[18]. Stating that ‘the description of information as ‘confidential’ is not altogether comfortable, information on an individualâ€⠄¢s private life would not, be called ‘confidential’. The more natural description is that such information is private and is better encapsulated now as misuse of private information[19]. By contrast, the misuse of private information is directly aligned to the protection of private information which is governed by the Data Protection Act 1998 providing regulation of the processing of information relating to individuals including the obtaining, holding, use or disclosure of such information[20]. Meaning the claimant only needs to establish a reasonable exception to privacy with the information in question. This is a clear juxtaposition to pre HRA as the balancing act is tipping in favour of Article 8. For instance, when John Terry[21] applied for an injunction to restrain a publication of details about his extra marital affairs, the person possessing the information is referred to as ‘persons unknown’. Although, the judge did not uphold the injunction, he firmly established that if there was a real risk that intrusive details about Mr Terry’s relationship in the article, he would have ordered that publication be prohibited. The development of this breach is therefore the underlying foundations to a kind of tort of privacy. The media were therefore undoubtedly concerned about results of these cases calling for a comprehensive legislation which the media have always adamantly discouraged. As suggesting tougher sanctions on what is considered private could potentially ‘gag’ them from any form of investigative journalism in fear of legal letters over any individual who claims they have had their privacy invaded. This claim can be related to The Bureau of Investigative Journalismwho published a story about two Staffordshire NHS surgeons, Mr Hutchinson and Mr Ravikumar. These surgeons had been criticised over deaths at then Britains worst hospital and yet did still carrying out operations without patients knowing about their record. The paper that was running the story backed off running the piece due to a legal letter from the lawyers claiming the information was plainly private information[22]. Clearly, this valuable investigation should be able to be published without fear of prejudice, as ef fectively the only thing that is being hindered is the truth[23]. It seems the evolution of the judge-made law of misuse of private information has allowed less known individuals, children[24] and vulnerable adults (under the mental health act) to be protected against privacy infringements by the media. Yet, it also seems this area of law has become disproportionately swamped by vanity driven celebrities complaining about photos taken by paparazzi’s[25]. There is no disregarding the significance of the Campbell case as it has established several important precedents, but what it seems that injunctions have become only the rich and powerful are able to fend off the media. These gagging orders have stopped newspapers reporting allegations of everything from extramarital affairs to legal disputes. Premiership footballers, actors, television personalities, bankers and celebrity chefs are among those who have successfully used the courts to stop such disclosures entering the public domain[26]. So where does this leave article 10 of the HRA in rel ation to the balancing act? Because as stated earlier in this analysis neither articles have precedent over each other. Yet, these gagging orders which have become a common phenomenon is highlighting that something is failing. Take McKennitt v Ash[27] when the court ruled someones right to protect their private life outweighs someone elses freedom to tell their story it cast shadow over the media industry. So following the historic 3:2 decision in the Lords, it should now be addressed of where do we go from here? Despite some feeling that the Wainwright and Campbell case could signal a completion of the development of a new remedy in English private law. It seems that these cases have merely become a staging post on route to the evolution of a fully-fledged tort[28]. However, a A symbolic case that demonstrates the delicate balance between the right to privacy and the freedom of expression post implementation of the misuse of private information lies with the Max Mosley case[29]. This case was brought to the courts attention on the 30, March 2008 when the News of the World published an article titled â€Å"F1 Boss Has a Sick Nazi Orgy with Hookers†[30], also making reference to Mosley being a sadomasochist Sex Pervert[31]. This judgment further tipped the balance in the favour of greater privacy where there was no public interest. As clearly this article was not in the public in terest as it did not affect the job and revealing immoral behaviour is not a legitimate public interest because it does not expose illegal wrong doings. Mosley won his privacy claim and award  £60,000, although Eady J in the Mosley case stated: â€Å"It has to be recognised that no amount of damages can fully compensate the claimant for the damage done. He is hardly exaggerating when he says that his life is ruined†[32]. It could be argued that the convention is therefore intended to guarantee rights that are practical and effective so injunctions against potential life changing stories are better to be blocked than to have a remedy of a substantial pay-out. In respect to the Campbell and Mosley decision it is clear that most media organisations and lawyers will agree that privacy is now based upon a case to case basis, which must be applied through confidentiality and the Human Rights Act. Whilst the verdict came as a damaging blow to media organisations, they can take solace in the statements from the dissenting judges for example Lord Nicholls and Hoffman expressed; â€Å"from a journalistic point of view, photographs are an essential part of the story. The picture carried the message, more strongly than anything in the text alone†¦in my opinion†¦should be allowed†[33]. Some however have vented their frustration that this development of a backdoor law is â€Å"driven by a deep loathing of the popular press, the judges have long been itching to bring in a privacy law by the back door. Thus free speech is to be made conditional on the prejudices of the judiciary†[34]. The reporting on private matters only became harder when the media’s reputation went into free fall during the Leveson inquiry of 2011, following the revelation that mainstream newspaper organisations had been tapping into phones of officials, celebrities and even the deceased in order to generate content. This subsequent down fall of the media brought from the ashes a new regulatory body which itself is responsible for the protection of privacy. This Royal Charter which was proposed appears on the face of things baring similar characteristics to the press complaints commission. Yet, there are some distinctive differences. Unlike the PCC the body will be an independent from both the judiciary and the press meaning it should allow a balanced decision. Furthermore an independent regulatory body that has the power to impose heavy sanctions (capped at  £1 million) will initiate the first step of weighting right to privacy over the freedom of the press. Furthermore, this leads onto the quintessential debate of who should be developing this law? Has Parliament failed to address this issue? Mr Justice Lindsay stated in the Zeta Jones case, â€Å"Parliament has failed so far to grasp the nettle†¦if Parliament doesn’t act soon the less satisfactory course of the Courts creating a law bit by bit†[35]. However, the HRA is not the only tort which has been passed through the Houses that deals with the issue of privacy. There are a number of overlapping Acts which address this issue. For example, the theSexual Offences Act add a criminal offence to the act of voyeurism, and, theProtection from Harassment Act creates both criminal sanctions and civil remedies against harassment, to which all have been employed in the decisions made by judges. So even though David Cameron has expressed his concern and ‘unease’ about judges formulating a law. It is difficult to suggest that even though Parliament has not legislat ed on privacy issues, reviewing the evidence it would be extremely difficult to draft a new or improve our existing laws. Without moving too far away from the restraints being held over the UK for being a member of the European Union. In conclusion, the liberty of the press is indeed an essential cornerstone of a free state; and to forbid this, is to destroy democracy[36]. However, Lord Denning accepted that even though this remains an absolute right it is still subject to limitations stating â€Å"the press shouldn’t be free to ruin a reputation, break confidence or to pollute the course of justice†[37]. To a large degree most if not all journalists and judges would accept this statement as ethically factual. So after examining the evolving tort throughout this essay with the various debates which have been highlighted by both journalists and the judiciary it is clear that some progress has been made as the ‘position for victims of shameful intrusions †¦ is better now than it ever was in the past’[38]. Appeals such as Wainwright v Home Office[39] and Mosley v News Group Newspapers Ltd[40] emphasise that over the past twenty three years something fundamental has happened into how we re protected. The induction of a HRA has ultimately been the spring board that has helped develop the law of privacy that protects us today. Even though there have of course been improvements made there still remains a significant way to go in regards to privacy in English law. For instance, there still contains many inconsistencies into how article 8 is applied to cases on such a broad scale this includes the recent judgment on ZH v The Commissioner of Police for the Metropolis[41] as at trial, Sir Robert Nelson held the police liable in tort assault, battery, and false imprisonment and trespasses to the person. The judge also identified the police as having breached the HRA; inhuman and degrading treatment (article.3); deprivation of liberty (article.5); and privacy (artcle.8). Which given the past history of cases would have been dismissed by some English law judges. Finally, what this essay finds is that for every wrong there is a remedy. Trespass, Nuisance Defamation, malicious falsehood, Breach of confidence, Protection from Harassment and Data Protection Act 1998 so whilst there are piecemeal protections, why do judges or parliament need to make a grand step?[42] [1] Hertfordshire law Journal 2(2), 30 [2] [2003] UKHL 53 [3] Harris, O‘Boyle and Warbrick, 2009, p 31 [4] Report of the Committee on Privacy and Related Matters, London: HMSO, at 7. [5] Cooley on Torts, 2nd ed (1888), p29 [6] [7] [8] Court of Appeal Kaye v Robertson and Sports Newspapers Ltd[1991] FSR 62 [9] Prince Albert –v- Strange : [1849] 1 HT 1 [10] Coco –v- A N Clark (Engineers) Limited : 1969 [RPC 41,47] [11] Attorney General –v- Guardian Newspapers [1999] 1AC 109 [12] [1984] 1 WLR 892 [13] Douglas and Zeta Jones Ors –v- Hello : [2001] QB 967, 997 CA Sedley LJ [14] Hertfordshire law Journal 2(2), 30-40 [15] [16] [17] Naomi Campbell –v-MGN Limited: [2004] UKHL 22 [18] Ibid [2004] UKHL 22 [19] Ibid [2004] UKHL 22 [20] Plymouth Law and Criminal Justice Review (2014) p182 [21] John Terry(previously LNS) vPersons Unknown[2010] EWHC 119 [22] [23] [24] [25] [26] [27] [28] [29] [30] [31] [32] [33] [34] [35] [36] British Steel Corporation v Granada Television Ltd [1981] AC 1096. [37] Ibid AC 1096 [38] [39] [40] [41] [42]

Tourism PESTEL Analysis | Canary Islands

Tourism PESTEL Analysis | Canary Islands PESTEL PESTEL as acronym stands for political, economic, social, technological, environmental and legal factors, which influence the processes within a n organization. It is an analysis, which concentrate on the environmental factors that influence the operational firm. Therefore, it is a mandatory and helping tool for managers to have better insights about the threats and opportunities and understand its majority that exist in a running business, which are affected by such factors. This analysis thus, provides a greater vision for managers for current and future purposes to compete on the market completely and effectively. The understanding of the environment that influences the business is crucial to have an overview and control of the organization to manage the plans with environmental effects. The firm, which does neglect the forces of environmental changes, hardly succeeds and survives the competition. The right apprehension of Pestel also provides a great strategy to managers about th e existing external forces that affecting the business environment. (P)olitical factors The political environment that exists in a nation can have tremendous impacts on the execution of a business including the lodging business. Governmental issues influence the day-by-day lives of numerous subjects all over the Canary Islands and companies it is a must to develop ways to adjust to the political circumstances in the nation. The political methodology received by a nation influences the quantity of nearby guests and their capacity to go around the nation. The hotel industry of Canary Islands is highly dependent on the local and international visitors. Year by year, the Canary Islands has been captivates a great amount of tourist from abroad. Canary Islands are Autonomous groups of Spain with a membership as well in the European Union. In the Council Decision of 20 June 2002 (2002/546/EC), taken on the basis of Article 299(2) of the EC Treaty, the Kingdom of Spain was authorised from 1 January 2002 until 31 December 2011 to exempt or reduce partially from the AIEM tax (Arbitrio sobre las Importaciones y Entregas de Mercancias en las islas Canarias) some products produced locally in the Canary Islands. The AIEM tax is generally imposed on products imported into or obtained in the Canary Islands. In the annex to the Council Decision is the list of products to which the above mentioned special measure applies. The difference in taxation between goods taxed on a regular basis and those to which is applied an exemption or partial reduction cannot be higher then 5%, 15% or 25% depending on the product. In the Council Decision of 20 June 2002 the reasons underlying the adoption of the special arrangements were presented. The main sources of the problems faced by the Canary Islands are isolation and fragmentation of the market. This causes various difficulties mainly connected with higher production costs (transport, energy, supplies of raw materials, treatment of waste, etc). It also contributes to the low diversification of the economy which is weaker and more susceptible to negative changes than European and global markets. In other words the special measures were introduced to counter disadvantages faced by the Canary Islands and thereby allowing the economy of the Islands to develop. They were especially targeted at strengthening domestic industry by increasing its competitive position, which is disadvantaged because of the location, structure and size of the market. Also, they are unable to benefit from globalisation. The AIEM aims at reducing those disadvantages of the market of the Canary Islands. Data provided by the Spanish Government shows that positive effects were observed after the special measures were introduced, however the problems underlying the special tax scheme continue to exist. Therefore continuation of special measures is justified. http://eur-lex.europa.eu/resource.html?uri=cellar:777c256b-adfe-11e3-86f9-01aa75ed71a1.0002.01/DOC_1format=PDF (E)conomic factors The second factor, which influences the working process and the accomplishment of Hotel Costa Calero is the economic ones. GDP growth forecast for 2015 and 2016 to 3.3% and 3.0% respectively. Overall, the greater economic dynamism encourages the creation of more than 60 000 jobs in the biennium 2015- 2016. the consolidation of the price of a barrel of oil at relatively low levels compared to the average of 2014 can be a significant boost to the Islands economy in 2015 and 2016 the European Central Bank surprised with a policy of quantitative expansion of higher volume than expected, and has left open the date of termination of the program. These actions will promote a reduction in financing costs to the private sector, especially in economies such as Spanish where fragmentation of the European financial system resulted in higher interest rates for households and firms in other eurozone countries. This will support growth in new credit operations and enhance the good performance of domestic demand. Depreciation of the euro against the dollar, that will put the exchange rate around $ 1.1 / â‚ ¬ 2015 on average BBVA Research estimates suggest that this depreciation of the euro 20% of its value in 2014 could boost the 0.8 pp Islands economy in 2015, the result of improved export competitiveness Canary faces several challenges, most notably an unemployment rate still above 30%. Return the regional appeal, increase the participation rate of young people and, above all, of those over 54 (see Box 3) and accelerate job creation consistent with increases in productivity must be considered a primary goal for the sake of reverse the divergence of per capita income about major European regions. On the revenue side, the approved budget reflects an increase in non-interest income of 3.5% compared to the initial forecasts of 2014, driven by increased resources Economic and Fiscal Regime of the Canary Islands (REF), which will be helped by the recovery in consumption and changes policy of the Tax on imports and delivery of goods in the Canary Islands (AIEM). The tourism sector is the main engine of the Islands economy (around 30% of GDP ) and, during the last five years, 2014 closed again, posting record figures in the number of visitors. Indeed, the Canaries received 11.4 million foreign tourists, up 8% from the previous year. By country, the UK (4 million) and Germany (2.7 million), remain the main source markets. Moreover, total tourist spending in the region also set a record with more than 14,200 million euros. This represents an increase of 7.1% %, the fall in the average stay (-0.3 days) it is primarily responsible for this development. Also, other factors help explain this phenomenon. Although geographically, the fall of stay has been widespread among the major source markets, this decline has been most pronounced among travelers aged between 45 and 64 years and tourists with high income levels, which added a decrease in daily spending, https://www.bbvaresearch.com/wp-content/uploads/2015/04/Situacion_Canarias_Abr15_Cap31.pdf (S)ocial Factors Canary Islands have a population of 2.104.815 wherefrom Lanzarote dispose of 141.940 inhabitants. Major percentage of this population is from Spaniard origin (109.178 in Lanzarote) and the rest of includes of German, Italian, Romanian, Moroccan, English, Columbian and from Chinese origin (These major nationalities from the population of Lanzarote are noted in the paper by their number of beyond one thousand from the residential nationality origin in 2014 (datosdelanzarote.com, 2014)). http://www.datosdelanzarote.com/itemDetalles.asp?idFamilia=9idItem=6531 This means, that Lanzarote is a culturally multiple island due to its historically and up to present migration into the island/s. The age structure in the Canarias is as follows; the age group from the total population under 16 is 22.2%, in Lanzarote is 27.3%, the working force from age 16 and under 65 is 56.9 in the Canary islands and 63.1% in Lanzarote from the citizens and finally people of age above 65 is 20.9% in the Canarias and 9.6% in Lanzarote (ine.es, 2014 and datosdelanzarote.com, 2014). http://www.ine.es/jaxiT3/Datos.htm?t=2853 http://www.datosdelanzarote.com/itemDetalles.asp?idFamilia=6idItem=6648 Education in the Canary Islands is compulsory for children below the age of 16 (gobiernodecanarias.org, 2010), which is a free for this aged population. Primary education is compulsory, however the rate of school leavers is 35% of the population between age 18 and 24, which might be caused the inefficient share of knowledge, demands of skill obtaining, low levels of standard education, however, according to Social and Political Pact, by 2020-2025 85% of the population would be compulsory to dispose a certificate from intermediate education (ec.europa.eu, 2012). http://ec.europa.eu/regional_policy/sources/docgener/studies/pdf/rup_migratory/canarias/ex_sum_canary_en.pdf http://www.gobiernodecanarias.org/educacion/5/DGOIE/PublicaCE/docsup/Estudiar_en_Canarias_Ingles.pdf (T)echnology Technology is one of the variables that could directly influence the business operations. The use of development in IT helps to maintain a smooth communication and operation in the organization and with customers as well. It largely influences the marketing and promotion of the products, so the say the service. The way of communication is changing to web based techniques. Hotel Costa Calero can be reached through their official website and social media such as Facebook, however their website should develop their channel, because of their discomposing appearance from their disordered outlook. The location of Canary Islands make possible to get around it by plane only. There are eight airports altogether in the Canary Islands and have an extensive network of highways. Numerous airlines established long distance flights to the islands such as its low budget known Ryanair, which is a great opportunity for those visitors who have limited budget for vacations. There are large ferryboats that link islands as well as fast ferries linking most of the islands. The increased use of tablets and smartphones is creating a convergence of e- and m-payments. M-payments are increasing at a rapid pace with non-banks slowly increasing their share of transactions. From 2011-2015, m-payments are expected to grow by 60.8% to 47.0 billion transactions. The mobile payments space is increasingly competitive, with banks and non-banks striving for market dominance and consumer loyalty. The slight slowdown in e-payments growth (from 19.2% in 2012 to 15.4% in 2013, a total of 29.3 billion transactions) has been due to a shift towards m-payments use, driven by increased penetration of smart phones and the internet, advancements in technology, and innovative products and services. Going forward, e-payment transactions are expected to grow in Europe as progress is made on the European Union’s revised Payments Services Directive (PSD II). https://www.worldpaymentsreport.com/The-Convergence-of-E-and-M-Payments The Canary Islands have been able to transfer successfully to their African neighbours their own expertise and technological developments, mainly in the renewable energy and water technology sectors, for providing basic services such as electrification and water supply services to isolated rural communities. The Canary Islands Government is deploying in the region technology parks specialising in adaptive technologies for development. Water treatment:production of 600,000 m3desalinated water per day. The first desalinating plant in Spain was inaugurated in Lanzarote in 1965. Solar energy:more than 2,500 sunlight hours per year, with a radiation of 5-6 KWh/m2per day. Photovoltaic systems operate with the production of more than 1,700 hours. Wind power:constant winds with average speeds of 6 to 8 m/s provide wind farms the equivalent to 3,000-4,000 wind hours. Geothermal energy:there are two projects currently in progress. These renewable energies can be implemented into the hotel industry to Hotel Costa Calero specifically for electricity purposes and to expand and develop it to other firms and association for variant countries. http://www.canaryislandshub.com/en-us/sectors/naturallaboratory.aspx (E)nvironmental factors This factor became important in the last fifteen years because of increasing scarcity of raw material, pollution targets, doing business as an ethical and sustainable company, carbon footprint targets set by government. These are just some of the issues marketers are facing within this sector. More and more consumers are demanding that the products they buy are sources ethically and if possible from a sustainable source. The European Union emphasizes waste management as one of the most important issue of political movement with the elementary factors such as reduction in the volume of waste generated, optimization of recycling, reuse and safe disposal. Waste treatment Waste treatment companies2 , both of urban and non-urban origin, managed 44.9 million tonnes of waste in the year 2012, which is 10.0% more than the previous year. 96.1% of the managed waste corresponded to non-hazardous category, reaching 43.1 million tonnes (10.9% more than in 2011). Conversely, hazardous waste stood at 1.8 million tonnes (8.6% less than in 2011). Of the total waste, 53.6% was sent for recycling, 39.6% for dumping and 6.8% for incineration. In total, 24.1 million tonnes of waste were recycled in 2012, the main categories being Metallic (10.1 million tonnes), Paper and cardboard (4.9 millions) and Animal and plant (2.2 million) waste. In the Canary Islands altogether the population created 44.9 million tonnes of waste in 2012, which is increased compared with the previous year with 10%. 96.1% of the gathered waste complemented to non-hazardous category, which 43.1 million tones from the total. The hazardous waste from the total was 1.8 million tons. From the total waste 53.6 % was processed in recycling mode, 39.6 % was dumped and 6.8% was incinerated. This means, in total 24.1 million tons was recycled in 2012 wherefrom the waste was metallic (10.1 M), paper and cardboard (4.9 M) and animal and plant (2.2 M). (L)egal factor The Canary Islands have extremely transparent fiscal regulations, fully approved by the European Union and Double Treaty Agreements signed by Spain. Recently, several actions have been adopted to combat tax avoidance and offshore tax As an European region, the Canary Islands are subject to the European legal system, and, as an autonomous community of the Kingdom of Spain, all the national regulations are applicable in their territory. The EU legal system has one of the highest standards of international legal security, which results in higher protection for companies based in the Canary Islands in many aspects, including data protection, free competition and financial regulations, evasion by the OECD and the G20 governments. These transparent fiscal regulations , administered by the Economic and Fiscal Regimen of the Canary Islands (REF), benefit companies through legal process cost reductions. Instead of VAT, Canary Islands use IGIC, which is an indirect tax and it makes possible to create and sustain efficient businesses among different countries that dispose with the ease and balance the isolated geographical location of the Canarias. http://ec.europa.eu/regional_policy/sources/activity/outermost/doc/plan_action_strategique_eu2020_canarias_en.pdf Moreover, currently Costa Calero lacks of the mobile application service, which might be advised to keep up with this technological trend.

Faith, Reason, and Imagination Essay -- Christianity

Each of our faiths and reasoning are based on our cultural beliefs, behavior, and how we come to rationalize sense in our lives; along with a belief that does not require proof. Reason holds justification and intellectual faculty by which our conclusions are based via a truth or non-truth in why we are faithful. The enriched imagination that one holds is part of that â€Å"something special† which helps progress our lives to the next level giving freedom to feel, think, and wonder all the possibilities of life has to offer. Our existence as humans has allowed us this pleasure without reservation. Faith and imagination is all about truth and the belief in a higher power beyond man himself. Faith and imagination binds the power of God’s existence. However, in lack of evidence and that which is unforeseen; consequently, if we know the value of life and understand that which is right and wrong; it truly acknowledges God’s presence among us. when people reference a â€Å"miracle† has happened; most people that hold faith as a powerful source don’t just assume the miracle came out of nowhere without some concept of a divine attribute connected to faith. A miracle is not an act based purely on a violation of natural law, but an act of God’s law and his true existence. And if man is to find his true purpose of his existence and fulfilling his life, he must adopt faith and reason. I feel that Faith and reason are correlated in many aspects, and are vital to one another. Reason precedes faith in the process of knowing God’s existence and reigning power; although one cannot truly know the reasoning of something to be known without knowledge first. Faith is built on spirituality surrounding one’s cultural beliefs, behaviors, and ... ... Our faith as Christians should be in the ability to hold firmly and trust in the revelation of God’s word. Revelation must not be ignored. The Faith â€Å"surrounds† our reason with three key elements in mind, which are focused on human life, and God’s mysterious existence and power. Faith is justified in our reason and not just a state of mind to fill the void of reasoned knowledge. I believe there is a special knowledge that is centered and leads us to truth---and reason toward our obligations, commitments and how dedicated we are in Christ. He will certainly open the path of life for those who faithfully believe the inner testimony and followed his word. Work Cited The New Oxford Annotated Bible: With the Apocryphal/Deuterocanonical Books, New Revised Standard Version. Michael D. Coogan, editor. New York: Oxford UP, 2001. Print.

E.P Thompsons The making of the English Working Class Essay -- Thomps

E.P Thompson's The making of the English Working Class From looking at The making of the English Working Class it seems quite obvious that E.P Thompson’s main arguments throughout his book are about the notion of ‘class’, in particular the ‘making of the working class’ ; and in order to evaluate his theories we must attempt to look at other historians opinions about his book, and his suggested theories, in order to come to an impartial evaluation. Many historians have their own interpretations when trying to define class, like Bourke who links class to characteristics such as accent, clothing; Marx who states that class was ‘no more or less than an objective social category’; and E.P.Thompson’s definition, that class happens ‘as a result of class conscious experience.’ Therefore it is quite clear that class is a contested concept as there is no exact definition, thus making it more difficult for historians to come to a conclusion with evidence to prove it. The Making of the English Working Class is according to Kaye and McClelland, ‘the obligatory starting point for any contemporary discussion of the history of the working-class formation.’ This gives us the indication that Thompson had not just written another piece on the concepts of class but that his book ‘opened interpretive eyes to a new way of seeing class.’ In his book Thompson’s main purpose was to write adjacent to the grain of economic history by implying that ‘the working class did not rise like the sun at the appointed time. It was present in its own making.’ In this we can see how Thompson seems to envoke the working class experience in a vivid way, which is arguably one of the reasons why his book received such appraise. However his book also received much criticism, as Kaye and McClelland point that his ‘own theory of how class formation is determined remains highly ambiguous.’ This suggests that perhaps Thompson did not go into specific detail on how class was formed and when, which remains a highly debated topic. The fact that Thompson argues ‘thus the working- class presence was, in 1832, the most significant factor in British political life’, is argued by the Marxist historian Anderson, that class was not specifically made in the 1830’s due to its decline, but was perhaps made in the 1880’s. The fact that he insinuates that the English working class was not ‘made’ by the ... ...analysed the ‘master narrative’ in order to come to the conclusion that ‘the terminology of class was not the favoured language of radicals in Thompson’s period and after, rather the construct ‘the people’ predominated and tended towards inclusiveness and harmony between classes.’ From looking at various historians opinions regarding E.P.Thompson’s book The making of the English Working Class, it is quite evident that there are many opposing views about his work that have led to many criticisms as well as many appraisals. The topic of class is highly debatable due to the fact there is no specific definition of it. It is also debateable where it originated from and so we cannot just look at one historian’s interpretation of the subject but we need to look at many in order to come to our own conclusions of the concept of ‘class consciousnesses and ‘class identity’. Thompson has produced an ‘outstanding’ interpretation of his theories on what made the working class and many historians have made valid criticisms that allow us to question some of his main arguments within the book, meaning that the notion of class is still a contested concept for which there is no specific answer.

All Quiet on the Western Front :: essays research papers

  Ã‚  Ã‚  Ã‚  Ã‚  Paul Baumer is the protagonist in All Quiet on the Western Front written by Erich Maria Remarque. Paul changes his values throughout the novel as a result of having to adapt in order to survive. As Baumer struggles to survive the war, he transforms as shown by his thoughts, actions, and the conversations that he contributes in.   Ã‚  Ã‚  Ã‚  Ã‚   One way that Paul changes is that his patriotism towards his country about war decreases. Paul is sitting with his men around a fire picking off lice and comparing them before throwing them in the fire. Muller starts to ask others what they would do if and when the war is over. After dwelling on the topic for a while they realized the younger men do not know how to do anything but fight. They joined the war at such a young age that they did not get a chance to explore anything else. â€Å"‘The war has ruined us for everything.’† At the beginning of the novel he is excited about defending his country and destroying the enemy, but after having interaction with soldiers from the opposing side he realizes that they are all the same. They are just soldiers fighting for their countries and eager to get home. Paul’s experience in combat changes his thoughts of war. Because of this, he gains the ability to reflect on the events that happen. His own ideas of war changes when he first witnesses the ugly truth of war. Paul’s first experience in combat reveals to him that everything he was taught as a young recruit are lies. This causes him to make his own conclusions and thoughts about the war. As the war goes on, Paul realizes more and more about the reality of the situation that he is in.   Ã‚  Ã‚  Ã‚  Ã‚  Paul loses his innocence and childhood during the war; as a result, he becomes a man. In chapter seven, there is a scene where Paul, Leer, Kropp, and Tjaden swims. Three French women walk on the river bank. Paul and the others make hand motions with a loaf of bread and spoke in broken French. They make plans to meet the girls later that night. â€Å"We call out to them that we would like to come; sometimes when the guards cannot see us...we assure them that we will bring some with us... and other tasty bits too.† (Remarque 145) Through this trade, Paul uses the women for his urges.

Lijjat Papad

Shri Mahila Griha Udyog Lijjat papad popularly known as â€Å"Lijjat† is woman’s organization manufacturing different products such as Papad, Khakhra, Appalam, Masala, Vadi, Gehu Atta, Bakery Products, Chapati, SASA Detergent Powder, SASA Detergent Cake (Tikia), SASA Nilam Detergent Powder, SASA Liquid Detergent. It is an organization of the women, by the women and for the women. The turning point of the institution was in 1966 when it was registered under the Bombay Public Trust act 1950 and also registered societies registration Act, 1860 and it’s recognized by Khadi & Village Industries Commission as a village industry.The objective of the institution is to provide employment to the ladies to enable them to earn decent and dignified livelihood. Any women who can render physical work in the institution without distinction of caste, creed and color and agrees to abide by the objective of the institution can become a member of the institution from the date on whi ch she starts working. Lijjat has a Central Managing Committee, which consist of 21 members out of whom they have 6 elected Office Bearers i. e. President, Vice President, 2 Secretaries and 2 Treasurers.Besides Lijjat Papad the Institution has other products like Masala, Detergent Powder, Cakes & Chapaties. At present it has 72 Branches & 27 Divisions and gives employment to about 42,000 sister members all over India with sales turnover of Rs. 650 crore which includes Rs. 30 crore from the Exports. The Institution, over the years, has paved the way for women to become self-reliant and self confident. Lijjat has provided them the right platform to improve their status in society. ? HISTORY It all began on 15th March 1959 which was a warm summer day.A majority of the women inhabitants of an old residential building in Girgaum (South Mumbai) were attending their usual domestic chores. A group of seven gathered on the terrace of the building and started rolling the bait. A handful of so cial workers were also present. The gathering was over soon after rolling of 4 packets of Papads and taking a firm decision to continue making papads. This function added a new chapter in the history. Shri Mahila griha Udyog Lijjat Papad was launched. It was a humble beginning.As the ays went by, the additions to this initial group began increasing. In those early days the path was not easy. The institution had its trials and tribulation. Faith and patience of the members were put to teat on several occasions. They had no money. Literally the Institution started from scratch, on borrowed sum of Rs. 80/- on the condition that it must earn and return Rs. 200/- within a stipulated time. The Institution has opted for the goal of self reliance and self growth from the very beginning. As a matter of principle no monetary help was to be sought from any quarter.Even voluntarily offered for donations were not to be accepted. So work started on commercial footing, as a small scale venture. Di fficulties and hurdles were there, but they were accepted by the members as test and trails of their convictions and they met them with a smile. What really helped the institution was excellent quality of papads, which has remained uniform from the very first day of its production. At no time the members have allowed it to deteriorate. The principles, upon which the institution is based, have made Lijjat Papad a successful organization

Analysis of The Movie “Patch Adams” Essay

The film opens. Patch has checked into a mental institution. His condition was depression. The environment looks like a jail cell, dark and depressing. During his stay, he realizes that the doctors did not help him in his recovery. Patch Adams’ psychologist was indifferent to the patients in general. The psychologist did not show any interest in his patient. Pach Adams’ psychologist seems to not have any interest in listening to Patch Adams’ feelings. In many cases, he is more interested in his cup of coffee. Patch Adams realizes that he is not being heard and lose the trust of his psychologist. He makes great friends at the mental institution; regardless of his condition, Patch Adams was able to help some of the patients at the mental institution. He started by showing interest in their problems and helping them to overcome their fears. Without studies, Patch Adams showed more skillfulness in listening and having a humanistic tool than the medical staff. Later, Patch Adams decided to become a doctor, which gave him a purpose in life. Patch Adams was very wise and happy man. Helping others made him cure his depression. As a medical student, he uses humor and happiness as medicine with the patients. Most of the students and professors did not like him at all. It was like when Bernie Sanders tried to convince Republicans and Democrats that they supposed to be working for the working people not only for the one percent. In addition, Patch Adams observed a lot of problems in the hospital. Nurses were not treated the same as doctors. Children who suffered from cancer passed in their rooms without joy and hope. Relatives of patients who had to fill out tedious forms instead of being with relatives in life or death situations. He had a revolutionary idea after seeing these problems. He wanted to have a system where patients were not seen as a business because doctors should act more human when they treat their patients. He wanted to help them to b e healed not only of their illnesses but also of their social problems. After many difficulties, he graduated as a doctor. INTRODUCTION Communication in a Healthcare setting is one of the most important tools. Communication skills are something that many individuals have to work on. Not everyone knows how to communicate effectively, especially when dealing with a variety of cultures. Physicians must master their skill communication to improve the patient’s experience. Communication is both verbal and physical. Communication has been shown to favorably affect clinical outcomes, patient adherence, patient satisfaction, and reduced malpractice risk. The movie is based on Dr. Adams’ real life. Dr. Adams’ fundamental idea is to make us understand that medical attention is not only about focusing on the problem or disease. The medical attention is also listening to the patients. Providers should help their patients in an integrated manner. Patients should be approach physically and emotionally as well. The film has many aspects of health communication. Some of them are therapeutic communication (patien t-center), communication empathy. active listening (empathy), and trust. The communication between Patch Adams and his patients is very deep. Patch Adams does not focus only on their pains or symptoms. Rather, he asks them about their lives, family, work, friends interests, etc. Therapeutic communication (Patient Center communication) is very important. It is not just about touch-feeling and more humanistic. Interrupting a patient prematurely closed-ended questions. When doctors do that they fail to address the patient’s concern’s and fail to really understand the patient’s full agenda for why they are seeking healthcare. Additionally, when doctors ignore personal information, patients get the idea that they are not being heard and that the doctor did not care about them. As a result, patients will not take their medication or follow the procedure that the doctor recommended. For instance, Patch Adams’ relationship with his psychologist was untrusty, resulting in the abandonment of treatment and distrusting the system of the do ctor and provider as well. This causes a lot of problem in our healthcare. On the other hand, when doctors use open-ended questions, it can be utilized to allow patients to freely talk about their own problems or feelings associated with the complication.† Open-ended general inquiries claim a lack of knowledge of patient’s problems, encourage their de-novo presentation, and frame patients (at least initially) as being active authorities over their own health information.† (Robinson, Heritage, 2005). Active Listening is different from just hearing and repeating what was heard. This skill can help us reveal not only what the patient is saying but what the patient is thinking and feeling (Servellen, pg. 91). Patch psychologist showed lack of this skill. When Patch was telling his childhood story about his dad death †Dad told Patch Adams at the Korean world hid dad lost his sold, all the time Patch Adams thought he was the one who lost his sold† The disconnection between psychologist and patient showed lack of empathy, focus, and attention. Patch Adams at the Medical School was able to display active listening to friends, patients, and classmates. Active listening requires providers not only to hear, but to listen; not only to see but to perceive; and not only to touch but to feel (Servellen, pg.92). Trust, I personally think that trust is the most important quality to get from patients. It is probably one of the most difficult quality to achieve and keep in these days. †Patients’ trust in providers usually evolves over time. Patients most of the time will self-disclosure until they observe that providers are acting on their behalf.† (Servellen, pg. 109). Building trust is very crucial for a good relationship and for the outcomes of the patients. For example, a patient who does not trust or like the practitioner will not disclose complete information efficiently. Patients who are anxious will not understand the instructions clearly (Dorr & Lipkin, pg. 4). Conclusion: The main reason for communication in the healthcare setting is not just to ask and collect information. Should be beyond, not only focusing on the problem of the patient, communication help us as well to establish trust and good relationship with patients. If we are able to gain the trust of our patients we can guarantee a good relationship and better outcomes for patients. If we gain trust Healthcare professionals will not feel fear to be transparent as a result our communication with patients will be fructose. Making patient participate in their care, in quality of life and have higher satisfaction.