The Guild's response to the consultation (pdf) can be downloaded in full. It starts by welcoming the chance to engage in a debate about copyright and then highlights the importance of protecting creators' rights.
We welcome the emphasis on the fact that the creative industries generate over 8 per cent of UK GDP and in 2006 accounted for over 1.9 million jobs. We would comment that creators (including writers) make up only a tiny minority of these jobs and indeed in many cases do not actually have jobs in the conventional sense, because they work as freelances. But although only a small fraction of the workforce, creators are important because their output is what makes the creative industries possible, and allows those hundreds of thousands of jobs to exist. Therefore it is imperative that creators’ interests are safeguarded and enhanced – our creators are the geese that lay the golden eggs.Each of the IPOs consultation questions are then addressed before the final paragraph argues against over-simplification:
There is a line of thought through this paper that seems to say that everything is too complicated and should all be made much simpler. In fact the principles of copyright and related rights are simple. What is complicated – and inevitably so – is the way the principles are applied in detail to different kinds of work – say a piece of music, a television programme, a computer game, a theatrical performance. In all these cases and many others, creators, their representatives, and exploiters have over time evolved practices and forms of contracts and licences that mostly work, and deal with a wide variety of eventualities. They are already doing just the same in the digital environment. We fear that a misguided attempt at “simplification” would result, paradoxically, in a more complicated and less effective system than we have now.