rights of persons involved in past and present court cases by means of a letter to all publishers distributing programmes dealing with such cases. This letter, which was passed on to the Contrôleur Général, contained the following paragraph: “The Independent Authority (Conseil) reminds you that freedom of communication and provision of information to the public through the broadcasting media does not exempt publishers from respect for the rights of persons mentioned on air, while ensuring that there is no infringement of their private life or of their image rights as defined under article 9 of the Civil Code (Code civil) […] and in the case of prisoners, regulated by article 41 of the Act of 24th November 2009”. There followed a reminder of the content of article 41 of the Act of 2009 which provides that: “Prisoners shall give their consent in writing to the broadcasting and use of their image or their voice when such broadcasting or use is likely to make it possible for them to be identified”. Following the meeting of June 2012 and the letter received, the Chairman of France Télévisions replied to the director of the CSA. According to his analyses, persons deprived of liberty cannot have the benefit of any “right to be forgotten” due to the consistency of laws and case law protecting freedom of information. Moreover, according to the Chairman of France Télévisions, the broadcasting of images from the past concerning the prisoner (for example excerpts from a film made on the day of their marriage more than twenty years before the date of broadcasting of the programme) is linked to a commentary tracing the principal aspects of their life and fully corresponds to the legitimate purpose of provision of information to the public. Finally, the Chairman of France Télévisions gives his own interpretation of article 41 of the Prisons Act of 2009: indeed, he considers that the latter only requires the prisoner’s consent to the broadcasting of their image or of their voice when the latter are recorded in prison. Yet the law is silent as to the place of recording of the images. It lays down the general principle that consent is obligatory if the person concerned is imprisoned and can be identified. For images filmed before their imprisonment, prisoners obviously retain rights over the use of their image. In this instance, it is indeed a question of protecting them against acts of violence or blackmail of which they could be the victim following the broadcasting of the programme. On this point, in spite of the commercial arguments that may be put forward in order to justify the continuation of programmes of this kind, the risks incurred by the persons involved require changes. 6. The Reform of the Act of 5th July 2011 concerning Psychiatric treatment without Consent The Act of 5th July 2011 concerning treatment without consent in the field of mental health was reformed by the Act of 27th September 2013. The reasons for this reform were indicated in the previous section (two provisions of the Act of 2011 were censured by means of a priority preliminary ruling on constitutionality) and how Parliament did not content itself with remedying these unconstitutional points but, on the basis of important work on the part of the social affairs committee of the French National Assembly and its rapporteur, put right a certain number of elements that needed to change83. 83 On which light had in part already been cast in a report on the implementation of the Act of 5th July 2011 drawn up by Messrs Serge Blisko and Guy Lefrand, Member of the French National Assembly (Assemblée nationale, XIIIème législature, rapport n° 4402). 76