Chapter 13 An online ombudsman?
There were divergent views on the merit of establishing an office of
online ombudsman to investigate, advocate and act on cyber-safety issues.
Those in favour saw the ombudsman as providing investigative and
advocacy functions as well as presenting an opportunity for a more visible and
centralised reporting place. Those opposing the proposal raised concerns about
duplication of existing facilities, the actual functions of the office,
jurisdictional considerations and timeliness of procedures. Some participants remained
undecided, perhaps because of uncertainty about the role of the ombudsman.
Role of an ombudsman
The Australian and New Zealand Ombudsman Association describes the term
‘ombudsman’ as being ‘understood by the public as signifying an independent
office, which primarily has a complaint handling and investigation function’.
The Australian University Cyberbullying Research Alliance defined an
a government official responsible for impartially
investigating citizens' complaints against a public authority or institution
and trying to bring about a fair settlement. 
The Australian and New Zealand Ombudsman Association stressed that:
It is important that members of the public are not confused
about what to expect when they approach an Ombudsman. Public trust in, and
respect for, the Ombudsman institution generally — and its independent dispute
resolution function specifically — must not be undermined. Neither should the
term Ombudsman be used in a way which distorts the appropriate character of an
It added that:
Where problems arise in an industry or an area of government
services, the call for an ombudsman commonly follows. In itself, this is not a
problem—indeed it is a testament to the high level of public respect for the
independence, integrity and impartiality of Ombudsman offices.
[However] using the term ombudsman to describe an office with
regulatory, disciplinary and/or prosecutorial functions confuses the role of
Ombudsman with that of a regulatory body.
The Association outlined six essential criteria expected of ombudsman
offices: independence, jurisdiction, powers, accessibility, procedural fairness
and accountability. The Telecommunications
Industry Ombudsman summarised these attributes as:
- independence - the office of the Ombudsman must be
established by legislation or as an incorporated or accredited body so that it
is independent of the organisations it investigates;
jurisdiction - the jurisdiction should be clearly defined
in legislation or in the document establishing the office and should generally
extend to the administrative actions or services of organisations falling
within the Ombudsman's jurisdiction;
powers - the Ombudsman must be able to investigate whether
an organisation within jurisdiction has acted fairly and reasonably in taking
or failing to take administrative action or in providing or failing to provide
accessibility - there must be no charge to a complainant
for the Ombudsman's investigation of a complaint;
procedural fairness - the actions of the Ombudsman and
staff must not give rise to a reasonable apprehension of partiality, bias or
accountability - the Ombudsman must be accountable to the
Parliament if it is a Parliamentary Ombudsman and to an independent board of
industry and consumer representatives if an Industry-based Ombudsman.
The Association called for stronger controls on the use of the term ‘ombudsman’.
The Telecommunications Industry Ombudsman added that, if the Committee
recommends the establishment of an ombudsman’s office, this should meet with
the criteria set out by the Australian and New Zealand Ombudsman Association.
if the body proposed is to have other functions - including
for example advocacy or regulatory functions - which would generally not be
compatible with the functions of an 'Ombudsman', the TIO would strongly
encourage that another and more appropriate title be used.
The Australian and New Zealand Ombudsman Association stressed that in
situations where the office of an ombudsman is under the direction or control
of an industry or a government minister, they are not independent.
For example, an Ombudsman office must be established as a
standalone body by way of its own Act or Constitution. Its primary
responsibility must be to resolve consumer/citizen disputes, independently,
fairly and reasonably and without direction.
The office must be truly independent from the bodies or
individuals about whom complaints are made. The Ombudsman must not be — nor be
able to be perceived as — an advocate for a special interest group, agency or
The Association commended the Benchmarks for Industry-Based Customer
Dispute Resolution Schemes as principles to be observed by offices which
provide an external dispute resolution service for consumer complaints.
The Attorney-General’s Department made the point that:
The power of an Ombudsman generally lies in his or her
ability to investigate complaints and then notify the relevant government
agency or the public of the findings. The Department notes that many of the
websites an Online Ombudsman would receive complaints about would have no, or
only a minimal, presence in Australia. Consideration will need to be given to
how an Australian Ombudsman could perform an effective oversight and
investigation role in this context.
The Department also notes that there are a range of agencies
that deal with complaints about the online environment including ACMA, the AFP,
ACCC and the Privacy Commissioner. In assessing the merits of establishing an
Online Ombudsman, it will be important to examine how the role of this new body
can be clearly delineated from the roles of existing agencies to ensure there
is no confusion about where to direct complaints or delays causing by adding
another layer to the current system.
Support for an online ombudsman
The Queensland Council of Parents and Citizens’ Associations supported the
establishment of an online ombudsman ‘to investigate, advocate and act on
cyber-safety issues’. Australian University
Cyberbullying Research Alliance also saw merit in this approach:
... to advocate and act on cyber-safety issues, and would
suggest that it could be structured in such a way that enables and promotes
engagement with education/academia/research, in addition to police and
industry. It would be important that it not be a figurehead solely for the police,
When appearing before the Senate Legal and Constitutional Affairs
Legislation Committee in March 2010, Ms Susan McLean was asked of the benefits
of having an online ombudsman who can advocate in respect of the social
networking sites to get results and to deal with offensive material. Ms McLean
I think that would be fabulous provided that he or she had
sufficient powers. If it were just someone saying, ‘Look, we’ve got a range of
issues here and we need the stuff taken down because it is clearly offensive,’
and they say, ‘Well, it’s within our operating guidelines and we self-report,’
you are not going to achieve anything. I think it is imperative that they be
equipped with the correct tools ... In the last 10 days I have had four calls
from people extremely distressed by the fact that they have repeatedly—in
excess of 10 times each—contacted Facebook to get content removed, being
threatening content against a principal, content against a schoolteacher ...—and
two high-profile AFL identities who have had impostor profiles set up. They
were all at their wit’s end given the fact that they had reported it and
reported it and nothing had been done, the content was still there. They were
concerned for the safety and welfare of the people that were attaching
themselves to friends on the impostors’ profiles. In the case of the principal
and the schoolteacher, there were serious welfare considerations as well. I
deal with this on a weekly basis. When I was a police officer I could do something
... Whilst the line on Facebook is ‘we take your privacy seriously and we will
actively look at your complaints and act promptly’, they do not. ... I think
that a government appointed official with some teeth and some power would be an
The Young People Big Voice group comprises 14 to 20 year olds and was
formed to provide advice to the Centre for Children and Young People by
advising and collaborating on research activities and advocating to Government
on important issues:
YPBV members are generally supportive of the idea of an
Online Ombudsman to investigate, advocate and act on cyber-safety issues. YPBV
recommend that one of the functions of an Online Ombudsman be to facilitate
Australian children to share their views on developing effective responses in
relation to issues of cyber-safety.
Mr Johann Trevaskis also supported the establishment of an ombudsman
If nothing else, it will offer a central collection point for
real data about cyber-safety issues, so that future government policy can be
based on good information about what cyber-safety issues arise and with what
Parents and/or children may be more comfortable reporting an
incident to an Ombudsman rather than to the police, which may be more intimidating
or may be perceived as an overreaction.
He also provided some qualifications in relation to:
- the necessity to implement procedures for the exchange of
information between the ombudsman and the police;
the Ombudsman can advocate with online service providers but any
attempt at enforcement is likely to be unhelpful (any breach of actual law
should be left to law enforcement and the justice system); and
statistical information about number and type of issues notified
to the Ombudsman (via whatever mechanism) should be reported annually to the
public, and to the parliament.
The System Administrators’ Guild of Australia supported the
establishment of an independent online ombudsman:
As in the telecommunications industry, the ombudsman’s
primary responsibility should be in advocating for users and other stakeholders
and in resolving user concerns. Further, SAGE-AU
believes that the ombudsman’s responsibility should be to advocate to
government and law enforcement, and within Internet centric industries, on matters
pertaining to Internet usage education and policing.
The Office of Youth South Australia saw the establishment of an
ombudsman office as a step towards addressing the lack of a:
clear agency responding to cyber-safety issues and quite a
bit of public confusion about who to go to for help. Additionally, there is
public concern that police responses are not always adequate and often when
people do seek help, there is little that can be done and the individual is
left feeling frustrated that there is no one to follow up and resolve their
Brilliant Digital Entertainment referred to the absence of an:
independent position that rises above the opposing position
and competing vendors that would enable on-line safety to become a fundamental
right rather than wishful thinking.
The proposed role of Online Ombudsman has the potential to
have a far reaching effect not only on the safety of on-line activity but also
make a positive contribution to Australia’s digital economy.
It called for the role to be sufficiently empowered to influence the online
environment and the powers of the ombudsman ‘to reach across a wide variety of
organisations and take innovative or creative actions’.
It further commented that:
In order to achieve the full potential of this role the
Ombudsman should have the capacity to influence or act jointly with a range of
stakeholder organisations such a law enforcement agencies, a variety of other
ombudsmen, certain government agencies and have enforceable investigative and
dispute resolution powers. The role should have the authority and obligation to
submit amicus curiae briefs in Court matters likely to have an impact or
otherwise influence the course of internet activity including e-commerce, law
enforcement and content distribution.
It was submitted to the Committee that an ombudsman could provide
‘another legal avenue to bring content providers like Google to heel when it
comes to upholding their Terms of Service’ and to deal with persistent spammers
through the appropriate channels. Further:
the legislation covering this would be very important to get
right, and give the Ombudsman certain powers of jurisdiction when it comes to
content. I believe that the Gutnick case could well be useful in this regard.
Expanding this decision into a workable visible law applying to the Internet in
Australia could have the world sitting up and taking notice. If we get it
right, we could set the standard for genuine and workable cyber safety.
Ms Catherine Davis from the Australian Education Union saw the online
ombudsman as part of potential measures to mitigate some of the anti-social
Those opposing the establishment of an ombudsman
The ACT Council of P & C Associations called for ‘a firm strategic
stance to pressure websites that are popular with children to introduce
sufficient privacy and safety protocols’ and stated that:
Council recognises that the government has limited power in
patrolling the internet and therefore it should take a moral stance against
offending websites rather than fund an online ombudsman.
The Council was not convinced that the position would have meaningful
power, and added that:
Unless a site is Australian
registered, an online ombudsman will have no power to enforce control over
online material or proceed with any further action. Illegal content on
Australian sites can already be raised with the ACMA. But, in terms of
offensive material, it is difficult to see how an ombudsman could have any
power to control what is posted on websites, particularly if hosted overseas.
The ACT Council of P & C’s Associations suggested a more productive
approach would be :
for the government to urge the
owners of websites to introduce additional safety measures to protect children.
For example, while only the page creators on facebook can delete a post made by
a member of a group, the government should pressure sites like facebook to
automatically hide comments by users if there are a number of “dislikes”. The
government has limited power in relation to patrolling the internet and
therefore it should take a moral stance rather than using funds to establish an
online ombudsman whose role will be mostly ineffective.
Yahoo!7 commented that:
We remain committed to making the Internet a
safer place for all users, especially those who are more vulnerable such as
children, and working with government and community stakeholders to take positive
steps forward in this respect. Whilst we would be very happy to consider
ways in which government, industry and relevant communities could work in a
more coordinated manner towards this goal, we are not convinced that the
appointment of an Online Ombudsman would be an effective step in the right
Yahoo!7 also referenced the work of industry in
promoting safe online environments for users:
At present, most of industry work both
individually and collectively with various government departments who have an
interest in cyber-safety and have informal processes in place to deal with
issues as they arise. All websites should have mechanisms in place which
allow users to report illegal or offensive content directly to them in order
that the content can be taken down expeditiously. We appreciate that
awareness of these mechanisms may not be top of mind for some people and the
Internet Industry Association is currently preparing a reference guide which
identifies how to escalate these sorts of issues for each of the more popular
social networking websites. We fear that the scope of work which
would logically be tasked to an Online Ombudsman may be duplicative and
ignorant of relationships and processes that are already in place. We are
also mindful of the fact that many of the more popular social networking
services (where safety concerns are of greater concern) are operated out of the
United States and an Online Ombudsman may not have jurisdiction to actually
compel these companies to take action where there has not been a breach of the
government, industry and community stakeholders could be better coordinated and
harnessed, we would rather see the investment that would be required to
establish an Online Ombudsman’s office used to supplement funding to existing
organizations that are doing very important work in this area such as law
enforcement agencies and the ACMA.
Telstra Corporation also made the point that:
the appointment of a separate Online Ombudsman is not
required but such a function could be co-ordinated by the Australian
Communications and Media Authority (ACMA) within the existing Australian
legislative framework. ... Telstra understands concerns about the need for a
cohesive, integrated contact point to investigate, advocate and act on
Cyber-Safety issues. In Telstra’s view this function could be co-ordinated by
the Australian Communications and Media Authority (ACMA) within the existing
Australian legislative framework, without the need to appoint a separate Online
Ombudsman. Challenges would arise in executing such a function and in ensuring
effective remedies given jurisdictional limitations in relation to content
hosted offshore. In this respect, the ACMA is well-positioned to coordinate
with its counterparts overseas. Cooperative and more informal processes
established between industry, the ACMA and Government will ensure that these
challenges can be managed quickly as they arise.
The Australian Library and Information Association believes that:
the Australian Communications and
Media Authority is already fulfilling the functions of an ombudsman such as
investigating, advocating and acting on cybersafety issues. Therefore, we do
not support the establishment of an Online Ombudsman which may cause confusion
for concerned parents and users in the community.
The Australian Federal Police (AFP) did not see a need for an additional
‘reporting point or investigative structure dedicated solely to cyber safety’:
Rather the need is
to consider an enhanced coordination, longer term evaluation and policy
synergies of existing or proposed cyber safety programs.
In response to a question on the usefulness of an online ombudsman,
Commander Taylor of the AFP told the Senate Legal and Constitutional Affairs Legislation
My concern would be that there is a possibility that crimes
would not be reported as quickly as they should be or could be. If parents are
concerned that an offence is occurring, we would want that to be reported as
quickly as possible so that any action that has to be taken can be taken. I am
not sure if an ombudsman could add anything further than the current regime we
have already got in place.
The Communications Council was of the opinion that:
rather than establishing a new body such as the Ombudsman,
which may make matters increasingly complex, options in which cyber safety
issues are tackled through existing structures should be explored... The
Council would support an option which would see relationships between existing enforcement
agencies and publishers be strengthened.
The Association of Independent Schools of South Australia commented
Whilst the safety of students in Independent schools is
paramount, member schools expressed concern that establishing an Online
Ombudsman may not be the most effective way to ensure students remain safe from
cyber-harm... The application of an administrative/regulatory approach to
cyber-safety is not considered the most appropriate risk management strategy.
This Association added that:
Exploration of the formation of a national an advisory group
to guide policy development and keeping a watching brief on the ‘bigger
picture’, particularly in regards to international research and policies. This
is an alternative to the establishment of an Online Ombudsman that the AISSA
The Internet Industry Association made the point that informed users
already have the ability to respond to misuse of social networking sites as
most popular social websites already have such services within their networks.
The Association also advised that:
At present, understanding and appreciation of such resources
is uneven. In conjunction with the Government, schools and the community, the
IIA proposes improved education on such facilities... The IIA understands the
case for an Online Ombudsman is inspired in part on the effectiveness of our
local telecommunications, banking, insurance and other utility ombudsman-like
In principle, they often operate as a ‘last resort’ grievance
service. This means that if a user complains to an ombudsman before taking
their complaint to the service that caused the issue in the first place, they
may only waste time getting their complaint processed. In other words, an
Ombudsman may add another layer of regulation which may slow the response time
for legitimate complaints to be dealt with by relevant providers.
We note that law enforcement agencies have generally praised
the responsiveness under existing informal protocols with the main social media
sites. We would not like to see anything undermine or add complexity to those
arrangements. There is no evidence of systemic failure such as to warrant the
establishment of such an office... In addition where a jurisdiction crosses
borders there is a risk that an Online Ombudsman may offer only symbolic
assurance as they may not have any powers beyond that of publicity where a
complaint is well-founded.
This Association did not support the ‘establishment of an online ombudsman
until it can be established that such a role will add value to online safety
and avoid adding delay to current processes’.
ninemsn stated that:
Our preliminary view is that an ombudsman would duplicate the
reporting mechanism already in place by ACMA in relation to inappropriate
content. In terms of the more pernicious online offences, ninemsn believes that
the Australian Federal Police remains the most appropriate forum for
investigation and prosecution.
Web Management InterActive Technologies commented that:
Until there is a framework which encourages a Protective
environment, any such position would run the risk of holding a great deal of
responsibility and yet have little in the way of mechanisms in which to achieve
any real goals. It would be a little like putting a policeman in the middle of
the highway with no uniform, no tools of the trade and no respect from the
passing traffic. There is much more to do before we reach the point of
establishing that position.
The jurisdiction of an ombudsman was also questioned because of
international online developments. The question was raised
as to what an online ombudsman regulates:
In circumstances where globally acceptable benchmarks for bad
conduct are breached, such as murder, theft, drug offences or other crime,
extradition treaties are entered into for the purposes of mutually dealing with
offenders. This spirit of cooperation between independent sovereign
jurisdictions who have the same or similar values about human behaviour, is not
repeatable when it comes to the Internet because of how different our approach
is... In circumstances where law has genuinely been broken, the police are
able to cooperate internationally with their counterparts overseas (our AFP are
well regarded internationally on these issues). What would an online ombudsman
bring to the situation?... An online ombudsman would be wholly ineffectual, or
be nothing more than a figurehead.
The Consultative Working Group on Cybersafety commented that:
Many websites operate on a global basis and often only have a
minimal presence in Australia. The CWG considers there would be significant
limitations as to what an Australian Ombudsman can legally oversight and report
on. In addition, without jurisdiction over sites hosted outside Australia, the
scheme would rely on voluntary compliance without any guarantees that this
would occur which would in turn undermine the effectiveness of an Online
The Working Group added that:
In Australia there are already several mechanisms for dealing
with online complaints established by the ACMA, the AFP, ACCC, and the Privacy
Commissioner. Establishing yet another mechanism may exacerbate existing
confusion in the minds of the public as to where to direct complaints and
potentially add time and complexity to complaint resolution without necessarily
improving outcomes for consumers. It would be necessary to clarify the existing
roles and look at ways of removing duplication if an Online Ombudsman were
It concluded that:
there are other ways to safeguard the interests of consumers,
as has occurred overseas. For example, the European Union’s Safer Social
Networking Principles, which most major social networking sites have signed up
to, provide an alternative and means of regulating the sector. Approaches such
as this need to explored further as they are more likely to include a larger
proportion of the internet community.
The Association of Independent Schools South Australia outlined a number
of existing mechanisms which facilitate the investigation and reporting on
The requirements of school registration set out by the
[Non-Government Schools Registration Board] ensure that child protection and
anti-bullying and harassment policies are in place in all schools to protect
students from harm, including cyber-harm.
The Association does not support duplication of policies and
processes. Enhanced red tape will not enhance the effectiveness of strategies
to ensure cyber-safety.
When serious incidents that compromise student safety occur,
the Police are contacted and take carriage of incidents. There is also
legislation in place to support victims of cyber harm, such as harassment and
At a local level, schools have developed policies to follow
when managing incidents of cyber-bullying and abuse. In incidents involving
students, there is usually a broader context that needs to be considered with
schools often being in the best position to consider this. Schools can
implement a supportive set of strategies, with the support of Police or others
if required, without the heavyhanded approach an Ombudsman may introduce.
Further, the Association of Independent Schools of South Australia did
not support the establishment of an ‘Online Ombudsman as the overarching
advocacy body for this area without further evidence to support that it would
have a positive impact on eliminating cyber-safety issues’, and added:
In issues between students, it is sometimes the case that the
aggrieved student and parents remain dissatisfied with the outcome, regardless
of the process taken. If an external body such as an Online Ombudsman is
readily available to handle complaints, parties may be less willing to resolve
the matter at a local school level. Schools are concerned that parents and
students may not use their best endeavours to resolve the issues at a school
level and escalate matters unnecessarily.
The AISSA also expresses concern that an Online Ombudsman may
not be the most efficient administrative process by which to report incidents
of cyber harm. It may in fact slow down the process of reporting, investigating
and acting upon issues, when cyber-safety is an area that moves rapidly and
needs to be constantly monitored and managed. In addition, schools may be
reluctant to involve an Ombudsman because of the perceived additional
administrative duties associated with this process. Teachers may also be
confused about their role in the investigation and management of incidents
because of a perception that an Ombudsman will solve the problem. Consequently,
incidents may go undetected, unreported and unresolved.
The Association is also concerned about the negative impact
on young people resulting from being involved in a legalistic process and the
associated administrative burden that would be generated.
The Department of Broadband, Communications and the Digital Economy
looking at the incidents that have led to the call for an
ombudsman. I am not aware of one incident where the material that was of
concern was not hosted on an offshore website, such as Facebook, which makes
the question of extraterritoriality very difficult. That is the first issue
that would have to be dealt with. The second side of it, as you have rightly
pointed out, is that there are already a number of Commonwealth agencies that
have a role in taking and dealing with complaints in this space, including the
ACMA, the AFP and the ACCC. We are not aware of a type of complaint in this
space that would not fall within the jurisdiction of one of those three
agencies—if it were not an extraterritoriality issue.
The Association of Independent Schools of South Australia would prefer
to see an:
Exploration of the formation of a national an advisory group
to guide policy development and keeping a watching brief on the ‘bigger
picture’, particularly in regards to international research and policies...
Currently in South Australia, mandatory reporting requirements exist for
teachers and others in relation to suspected physical, emotional and sexual
abuse and neglect. This could be extended to include online maltreatment or
abuse, though this would require extensive consultation and negotiation with
states. Any variation to the mandatory reporting laws would need to be
supported by adequate funded training of teachers to recognise and report
incidents of cyber-harm. This could be an alternative to introducing an Online
The Alannah and Madeline Foundation advocates a broad community change
approach to cyber-safety through the empowerment of young people and adults to
keep themselves safe and to deal with online risks. This includes the ability
to report and seek support when risks and potential harm are identified.
The Foundation added that:
When in immediate danger, the advice always given is to call
000. Children and young people are always encouraged to seek help from a
trusted adult. Help Line and Kids Helpline receive calls regarding
cyberbullying and cybersafety issues. Social networking sites also have
mechanisms on their sites for reporting cybersafety issues... There are
currently a number of other, more specialised, mechanisms for reporting cybersafety
issues, including reporting to the Australian Communications and Media
Authority (ACMA) issues around cybersafety and inappropriate content, reporting
to the Privacy Commission concerns around breaches of privacy, reporting to the
Australian Human Rights Commission complaints of discrimination and human
rights breaches, and reporting potential criminal activity and illegal content
to the Australian Federal Police.
The Foundation advocated that any new mechanism being considered for
investigating, advocating and acting on cybersafety issues should consider the
significant resources, support and expertise already available and ‘should
include how these current mechanisms can be better harnessed, coordinated and
Rather, the existing avenues of complaint, reporting and redress could be
strengthen by an appropriate legal framework for bullying, cyberbullying and
other cyber-risks – a change that ‘is fundamental for an effective response to
Netbox Blue did not have a firm view on establishing an online
ombudsman, but saw that a similar office to the Banking, Insurance or
Telecommunications Industry Ombudsman may be helpful.
It qualified this by adding that:
the fact that legal jurisdiction is uncertain especially for
the most popular networking sites, could lead to merely another layer of
mediation without any real power.
Netbox Blue also cautioned that:
It is something that would require legal coordination across
several international borders. It would be useful to clarify where the gap
exists and how an online ombudsman can fulfil such roles as against other
mediation options available.
The Australian Communications Consumer Action Network commented that:
There are many different agencies involved in promoting
e-security and cyber-crime awareness – the ACCC, BDCDE, the Australian High
Tech Crime Centre – and we expect these agencies will have undertaken
assessments of the effectiveness of their campaigns and messages.
The Australian Education Union suggested ‘a feasibility study into the
role, powers and objectives of an online ombudsman in preference to a mandatory
ISP-level filtering policy.
Though undecided about an online ombudsman, Professor Bjorn Landfeldt
I believe that cyberbullying—and bullying as a wider matter
than just cyberbullying—is something that needs attention and more concerted
effort than putting out little fires here and there. The Children’s Ombudsman
in Sweden is a fantastic institution. It provides many more services. It
provides a safety net and a voice for children in society that I have not
experienced in Australia ... because children are well aware that the ombudsman
is a point of contact; everyone is aware of that. It is not hard to get to the
ombudsman as a child and go there with any concern. The ombudsman deals with
While there was considerable support throughout the Inquiry for a
centralised reporting authority, the evidence supporting the formation of an
online ombudsman position was mixed. Those strongly supporting the ombudsman
approach appeared to recommend such an office assume reporting, investigative
and advocacy roles, rather than those of an ombudsman per se.
It was not evident to the Committee that, in attempting to increase
cyber-safety for the community, evaluations of the effectiveness of existing
campaigns and the resultant proposals for improvement had been adequately
brought together for the benefit of stakeholders. Therefore there is a need for
better coordination. The question remains as to how a central organisation
should be managed and the designation of a formal figurehead. The role of an
ombudsman may be too restrictive to achieve this goal.