New Commonwealth advertising guidelines are unlikely to quench public interest in how governments justify campaigns. But the gradual shift to digital and online visibility points to more being done in-house, according to one mandarin — saving not just budgets but awkward explanations.
Department of Education and Training boss Lisa Paul faced questions at Estimates on the government’s most recent campaign to “address misconceptions” about the Coalition’s higher education reforms. The 10-week run of upbeat TV and radio spots (video above) launched less than a week after their university deregulation plans were defeated in the Senate. That campaign reflected the status quo of government advertising and its reliance on traditional mediums. But the latest campaign expenditure figures published by the Department of Finance late last month suggest that’s changing.
Commonwealth TV, radio and print advertising has continued to drop for the third year in row. Digital campaign spending has grown each year, although the growth in 2013/14 was marginal. A total of $106.5 million was spent on all campaign advertising, including $7.8 million on ethnic media and $1.8 million on indigenous media.
The 2013/14 expenditure was inflated across all mediums and audiences due to the $15.7 million spent on the 2013 federal election, twice the outlay of the 2010 election, and Defence Force Recruiting doubling its TV expenditure to $19.2 million. No other agency came close to spending as much as the Australian Electoral Commission or the ADF recruiting arm. Without those ubiquitous Defence Jobs TV ads aimed at networks’ most in-demand (and expensive) audience of young men and women, digital media buy would have by now overtaken all other Commonwealth advertising formats.
What these numbers don’t show, however, are how departments are using the digital transition to rebalance the way campaigns are run, using existing in-house resources to build and develop their own websites and social media fronts — still in the digital space, but without an outsourcing cost.
Education’s recent $14.6 million advertising campaign was accompanied by an information campaign including a website — highered.gov.au — Twitter and Facebook profiles with a Finance-approved budget of $1.3 million. Departmental secretary Paul said the information campaign budget is unlikely to be spent as it was being done by an in-house unit. That work and outlay was not included in the submission for Special Minister of State approval as it was outside the scope of the new advertising guidelines. Paul told the Estimates hearing:
“It was also done by the Shared Services Centre that we buy some of our corporate services from. There is a hopefully soon to be government-wide Shared Cervices Centre from which we buy all sorts of corporate services, including web services.”
The SSC also handles Education’s call centre work linked to the campaign. Despite $500,000 allocated to a dedicated higher education reform hotline, almost none of that budget will be spent since there was only 134 calls and the contact centre is paid by volume. Paul says engagement is instead now on social media and the website, a far cheaper method.
Paul said preliminary evaluation of the first two weeks of the campaign seemed to suggest some decreases in the prevalence of myths and misconceptions about the higher education system, also some slight increases in awareness of the reforms.
‘Objective, fair and accessible’
Finance’s new advertising campaign guidelines, in effect from February 1, won’t protect agency heads from having their motives questioned when choosing or directed to proceed with a campaign: they are, in short, so broad as to provide only fig leaf cover from claims of inappropriate use. The primary change is the re-introduction of an Independent Communications Committee that will consider proposed campaigns and report on compliance to judgement principles such as objectivity, relevance and absence of party political interests.
For advertising campaigns exceeding $250,000, proposals must be reviewed by the ICC and certified by the chief executive before ministerial sign-off. For smaller campaigns, the chief executive can choose whether to seek an ICC report.
The five principles — which apply to both advertising and information campaigns — have not changed, and provide a framework to guide public service agencies from partisan, premature, or ineffective targeting, but not so onerous as to be restrictive of legitimate aims. The principles are:
- Campaigns should be relevant to government responsibilities;
- Campaigns should be presented in an objective, fair and accessible manner and designed to meet the objectives of the campaign;
- Campaigns should be objective and not directed at promoting party political interests;
- Campaigns should be justified and undertaken in an efficient, effective and relevant manner; and
- Campaigns must comply with legal requirements, procurement policies and procedures.
The ICC will not certify campaigns against the fifth principle, and agencies must themselves ensure a clear audit trail and seek confirmation the campaign complies with laws such as broadcasting and media, privacy, intellectual property, electoral, trade practices, consumer protection and workplace relations.
Mandated research requirements, justifying the objectives of a campaign, remain in effect.
ICC-like bodies have not always saved governments from criticism, such as in Western Australia where Auditor-General Colin Murphy criticised the Independent Communications Review Committee for a conflict of interest. One of its members was also the state government’s top media strategist.
Paul was dragged into the debate between government and opposition senators during Estimates on the value of engaging in an advertising campaign involving public funded media buy before a policy has legislation passed. She told Estimates that not only did the interim guidelines permit it, it’s been the standard:
“I am not sure whether I dare, really … the technical answer to your question about whether a campaign is allowed when the legislation hasn’t been passed or enacted. The answer is yes, it is allowed. These guidelines allow it. Past guidelines have allowed it. I have certified such campaigns before. The interim guidelines say a cabinet decision which is intended to be implemented during the current Parliament. That is the cover there.”
The high education reforms campaign met that first principle to raise awareness of the existing system, Paul said, prior to changes, and encourages audiences to seek further information about current government resources, assistance and financial support for Australian higher education. Paul cited a precedent within the department too, such as the $21 million advertising campaign attached to the former government’s Better Schools program, which launched before legislation had passed:
“We always go through the same processes of seeking funds, doing market research, having a tender and then the creative and then the certification et cetera. The steps are all the same.
“Basically, the story is our people attended 46 open days in the middle of the year, talking to 8,000 prospective students and families. Many of those people thought that HECS was going to be abolished and that they would have to pay upfront fees. The market research confirmed that. The campaign is based around the market research in the normal way that creatives are based around the market research. I am confident in the certification.”
However, in the latest annual report figures, a majority of government advertising, research and public relations contracts falling under the guidelines were given to companies on existing panels. Just 20% of Commonwealth campaigns in 2013/14 were put to an open tender with more than one company invited.