is Talley Family v National Business Review 212 in which the then Complaints r eview Tribunal (now Human r ights r eview Tribunal) considered whether the publication of the �g ich List�h was a news activity. i t considered two approaches to the interpretation of news activity. First, a broad interpretation, under which the content of the publication is not analysed. The only question under this approach is whether the publication was part of an activity by the defendant broadly described as a news activity, as distinguishable from the news medium�fs other functions such as advertising and employing staff. The second possible approach involved analysing the content of the public public interest test to determine whether it is �gnews.�h The Tribunal found that on either approach the publication was a news activity. i t did not state clearly which was the correct approach.²¹³ Therefore, it is likely to be difficult to successfully complain to thep rivacy 3.17 Commissioner about a breach of privacy by the news media, except in relation to breaches of principles 6 and 7 by radio New Zealand or Television New Zealand. We note however that, although the news media are not bound by the a ct in relation to their news activities, the p rivacy Commissioner may inquire into and comment on media practices affecting the privacy of individuals, even where these relate to the media�fs news activities.²¹⁴ i n 2007 the Commissioner reported on her inquiry into the publication of photographs of elderly people and their carers in the journal of the New Zealand Nurses Organisation. The Commissioner noted that, while the journal fell within the definition of news medium and was therefore not subject to the a  ct�fs complaints provisions, she was empowered by section 13(1)(m) of the a  ct to inquire generally into any matter if it appears that individual privacy may be being infringed.²¹⁵ Complaints to Privacy Commissioner The information privacy principles are not enforceable in the courts. 3.18 216 r ather, breaches of the principles are dealt with through the complaints process outlined in this section. The exception is that the entitlement to access personal information in principle 6, where that information is held by a public sector agency, is a legal right and is enforceable in the courts.²¹⁷ a  ny person may make a complaint to the p rivacy Commissioner (�gthe 3.19 Commissioner�h) alleging that any action is or appears to be an interference with the privacy of an individual. For the purposes of a complaint, an action is an 212 (1997) 4 H r  NZ 72. 213 s ee also discussion in John Burrowsand u  rsula Cheer Media Law in New Zealand u  niversity p ress, Melbourne, 2005) 275-277; p  aul r  oth Privacy Law and Practice Wellington, last updated 2007) 214 p aul roth Privacy Law and Practice p  V  a  2.2(e). 215 Marie s  hroff, p  rivacy Commissioner �gCommissioner i nitiated i nquiry under s ection 13 of the p  rivacy a  ct 1993: p ublication of p 216 p rivacy a ct 1993, s 11(2). 217 p rivacy a ct 1993, s 11(1). 59 Invasion of Privacy: Penalties and Remedies