Chapter 6 - Adequacy of the guidelines for government advertising
In Chapters 2 and 3, the Committee noted that no
comprehensive statement of expenditure on government advertising and no
reasoned justification of the need for or evaluation of the effectiveness of
government advertising campaigns is made available, as a matter of routine
accountability, on the public record. The Committee also noted that the system
for appropriating funds for government advertising provides little restraint on
government spending in this area.
Given some of these deficiencies in accountability, the
Committee considers that there is a need for clear principles to be established
to provide guidance to officials, ministers and the Parliament about
appropriate practice for government advertising and information activities.
Accordingly, in this chapter, the Committee examines
the adequacy of the current guidelines covering Australian government
advertising, and considers the merits of proposed alternatives to these
The 1995 Guidelines
for Australian Government Information Activities: Principles and Procedures
(the guidelines) used by the Australian government were first promulgated in
February 1995 by the Keating Labor Government.
In evidence to the Committee, the Special Minister of
State, Senator the Hon. Eric Abetz,
maintained consistently that these guidelines do not require any revision or
updating. He said:
Given the criticisms of previous administrations with
advertising, the 1995 guidelines were set up and, in considering them, we think
they are pretty good guidelines.
A little later in evidence, he reiterated the point:
We, as a government, overlook the whole system and we think it
is working well. It is interesting that the principles and guidelines that we
are using have been adopted by state governments, which I think might be seen
as a bit of a tick of approval for them. You do not often get me saying this
but the Labor government do sometimes get things right and when they do get it
right we acknowledge it and we keep using it. We think that in 1995, in general
terms, they got it right.
In summary terms, the focus of the 1995 guidelines is
on providing for government information programs to be communicated effectively
to the whole community.
The guidelines emphasise the rights of all members of
the community to be informed about government programs, activities and policies
that affect them. They emphasise
the need for information to be conveyed in such a way that it effectively
communicates with the target audience as completely and impartially as
They identify groups within the community, such as
young people, the rural community, and those of non-English speaking
background, whose particular needs must be considered in the development of
information campaigns. The
guidelines set percentage quotas for the expenditure of campaign money on
advertising in non-English speaking media
and they specify that the portrayal of women, ethnic communities and Aboriginal
and Torres Strait Islander people must be 'realistic' and non-stereotypic,
showing them as integral participants in and contributors to Australian
Revising the 1995 guidelines
The Committee considers that the 1995 guidelines
effectively cover a range of issues concerning government information
activities that are important and relevant.
There are three reasons, however, for revising the
The first is that they are ten years old and were
written in a very different context. In 1995, continuous election campaigning
was not a feature of the Australian political process as it is now. Devolution
of accountability to agency level had not yet occurred. This means that matters
such as ensuring appropriate lines of process and accountability were not
written into the guidelines. Technologies, such as the internet and mobile
telephones, which were not widely used in 1995 are now key vehicles for
advertising and marketing.
The Committee notes that there have been major
revisions made by the Howard government in almost
every other area of law, regulation and practice. Given that fact, and given the vastly
different context in which the 1995 guidelines are now being applied, the
Committee does not accept Senator Abetz's
insistence that there is not one improvement, not one revision that could
possibly be justified in relation to these
The second is that, even as they stand, they are
routinely not being met.
The guidelines state that 'at least 7.5 per cent of the
campaign budget allocated to newspaper advertising must be devoted to
non-English newspapers. Similarly, at least 7.5 per cent of the campaign budget
allocated to radio advertising must be devoted to non-English radio'.
Information provided by PM&C indicated that this
target was not met in the case of newspaper advertising, and met only twice in
the eight years since 1996-97 in the case of radio advertising. The following
table illustrates the relevant percentages achieved.
Table 6.1: Percentage of campaign budgets allocated to non-English media
percentage allocated to non-English language newspapers
percentage allocated to non-English radio
Figures not available
Figures not available
Source: Department of the Prime Minister and Cabinet, answers to
questions on notice, 13 September 2005 (received 7 October 2005).
PM&C advised the Committee that Defence Force
Recruiting is exempt from the requirement to allocate 7.5% of the advertising
budget to non-English language newspapers and radio, that some campaigns in
specific locations are not serviced by non-English language media and that 'for
some large campaigns 7.5% expenditure would be excessive (eg. Taxation
The Committee questioned PM&C about whether these
caveats explain all the underspending on non-English language media, or whether
the 1995 guidelines are simply not being complied with. The Committee had not
received answers to these questions at the time of finalising this report. In
either case, the non-compliance suggests that the percentages allocated under
the guidelines are unnecessary and that the guidelines need revision.
The third reason for revising the 1995 guidelines is that
they are silent on the major question before this inquiry, namely the potential
for the misuse of government advertising for political advantage.
As the Auditor-General pointed out in his 1998 audit
about aspects of the government's pre-election GST advertising campaign, 'there
are currently no guidelines on the use of the central advertising system for party-political
advertising in particular, which distinguish between government program and
party political advertising'.
The Auditor-General noted then that, because of
concerns about precisely this issue internationally, 'many jurisdictions
recognise that ... there is a need for clear principles to be established to
provide guidance in this area'. He
endorsed this approach, saying that 'the development and adoption of
conventions, principles and guidelines that provide more specific guidance on
the use of government advertising would be helpful'.
This view was also adopted by the Senate Finance and
Public Administration Legislation Committee in its 2002 report on the so-called
'political honesty' bills. At that
time, the Committee agreed that there was strong evidence to support the
argument that arrangements for the regulation of the political content of
government advertising needed to be improved.
The Committee noted that:
the present guidelines on government advertising offer no
guidance to departments or ministers on the avoidance of political content in
government advertising campaigns.
The report noted too that the process of developing and
placing government advertising campaigns is administered by the Government
Communications Unit in PM&C, and decisions about the appropriateness of any
major or 'sensitive' campaign are made by the Ministerial Committee on
Government Communications. This means that it is 'the ministry itself which
determines what constitutes responsible use of the ministerial office in
relation to government advertising' and that, in the absence of any rules or
guidelines 'preventing the party political use of government advertising ...
decisions about content and presentation style are wholly in the power of the
Executive'. The government's own majority report then went on to say that:
This lack of guidance allows the party in government to conduct
government advertising campaigns, particularly in the lead up to an election,
without any reference to standards regarding the appropriate use of public
monies to promote government interests as distinct from party interests.
For that reason, the Senate Finance and Public
Administration Legislation Committee's 2002 report recommended revisions to the
1995 guidelines on government advertising.
The government did not implement that recommendation,
and appears to have resiled from the Committee's conclusions on this issue. As
noted earlier, Senator Abetz
maintained throughout this inquiry that there is no need for the current
guidelines to be revised. His argument was based on the claim that it had not
been proved that any of the current government's advertising campaigns were
party political, and therefore that there was no 'abuse' to correct.
The Committee does not accept the premise of Senator
Abetz's argument. However, even if that
premise were accepted, it does not constitute an argument against the need for
guidelines addressing the issue. This point was made cogently by Professor
Foundation Professor of Law, Griffith
University and Director, Key Centre
for Ethics, Law, Justice and Governance. He said:
it is obvious beyond repetition that accusations of the abuse of
government advertising are made by each side against the other and that the
prevalence of complaints has risen with the scale and gloss of government
advertising campaigns ... Each side considers that the other has abused the power
it has as government to provide spin rather than information. The logical
conclusion is that both agree that a temptation exists and that at least one
political party has given in to the temptation. One does not have to take sides
and agree with one party – or to say that each are right about the other.
The point is, Professor
Sampford concluded, that there is self-evidently
a temptation to abuse and there is a risk that governments will give in to the
temptation. There is almost universal agreement that at least one party has
given in to temptation. Therefore,
there is a need, in public policy terms, to implement arrangements which reduce
the likelihood of future governments succumbing to it.
As the Committee indicated in Chapter 1, irrespective
of whether there has been misuse of government advertising for party political
purposes by the current or previous federal governments, or state and territory
governments, good public administration and good ethical standards require a
robust accountability framework in this area.
Accordingly, the Committee considers that the need for
guidelines that specifically address the issue of the potential for the misuse
of taxpayer funded government advertising programs for party political purposes
In the next section of the report, the Committee
considers the principles and guidelines suggested by a number of different
reports, with a view to developing recommended guidelines for Australian
government advertising. In particular, the Committee considers the principles
and guidelines suggested by:
the 1998 Auditor-General report, Tax Reform: Community Education and
the 2000 Joint Committee of Public Accounts and
Audit (JCPAA) report, Guidelines for
Government Advertising; and
the 2002 Senate Finance and Public Administration
Legislation Committee (F & PA) report, Charter of Political Honesty Bill 2000 ; Electoral Amendment
(Political Honesty) Bill 2000 ; Provisions of the Government Advertising
(Objectivity, Fairness and Accountability) Bill 2000; Auditor of Parliamentary
Allowances and Entitlements Bill 2000 [No.2].
Auditor-General's principles and guidelines
The principles and guidelines suggested by the
Auditor-General were derived from guidelines adopted in New
Zealand and the United
Kingdom, and suggested as a result of
reviews of government advertising in Victoria, New
South Wales, Queensland,
Western Australia and British
They comprised two underlying principles and four guidelines.
The two underlying principles proposed were:
all members of the public have equal rights of
access to comprehensive information about government policies, programs and
services which affect their entitlements, rights and obligations, except where
providing this information would be a breach of government responsibility; and
governments may legitimately use public funds to
explain their policies, programs and services and to inform the public of their
obligations, rights and entitlements.
In summary terms, the four overarching guidelines
should be relevant to government responsibilities. Relevant considerations
under this heading are that an information strategy should be considered as a
routine and integral part of policy development and planning, and that no
campaign should be contemplated without identifying the need and target
audience through appropriate market research. Examples of suitable uses for
government advertising include: dissemination of scientific, medical or safety
information; provision of information to facilitate government accountability; provision
of information about new, existing or proposed government policies, programs or
should be presented in an objective and fair manner. This means that
information campaigns should be directed at providing 'objective, factual and
explanatory information', presented in an unbiased manner and capable of being
substantiated and independently verified. Recipients of information should be
able to distinguish clearly between facts and any comment, opinion and analysis,
and any comparisons made should not be misleading.
should not be liable to misrepresentation as party political. Material
should not intentionally promote or be perceived as promoting party-political
interests. Accordingly, it should be presented in unbiased and objective
language, not directly attacking or scorning the views of others such as
opposition parties, and should avoid using party political slogans or images,
including ministerial photographs.
of sensitive material should be controlled. As a general rule, material
that is politically controversial should not reach members of the public
unsolicited except where the information clearly and directly affects their
interests. Generally, such material may be issued only in response to direct
requests. Further, government advertising material should not be used or
reproduced by political parties in support of party-political activities
without 'appropriate approval'. Material should be produced and distributed in
a cost-effective manner, following a justifiable cost-benefit analysis. Thus,
objectives 'which have little prospect of being achieved, or which are likely
to be achieved only at disproportionate cost, should not be pursued without
good reasons'. Advertisements must comply with relevant law and with purchasing
and procurement policies.
Joint Committee of Public Accounts and Audit
In 2000, the Joint Committee of Public Accounts and
Audit (JCPAA) reviewed the Auditor-General's report and, in particular, his
proposed guidelines for government advertising. The then Chair of the
Committee, Mr Bob
noted in his foreword to the JCPAA's report that the issue of government
advertising guidelines is highly controversial in a party-political sense.
Nevertheless, he said, the Committee 'determined that it wished to produce
draft guidelines for Government to consider which, while not perfect nor
totally agreed by all Committee members, do represent the majority and largely
consensual views of the Committee'.
reported that the JCPAA took the guidelines suggested by the Auditor-General in
1998 as its starting point. It compared these proposed guidelines with the
existing 1995 guidelines, and with other guidelines in both Australian and
overseas jurisdictions. These included guidelines proposed by the Australasian
Council of Auditor-Generals, the audit offices of Queensland
and Victoria, and the guidelines
of the United Kingdom
and New Zealand
The main differences between the JCPAA draft guidelines
and those proposed by the Auditor-General are as follows:
the underlying principles include an additional
clause, stating specifically that 'government information programs shall not be
conducted for party-political purposes';
under the second sub-heading, 'Material should
be presented in an objective and fair manner', the JCPAA guidelines include
three additional dot points which address the accessibility of information to
disadvantaged individuals or groups. These new dot points essentially
incorporate the elements of the 1995 guidelines which require that particular
attention be given to the communication needs of young people, the rural
community and people of non-English speaking backgrounds, and also that
attention be given to the appropriate portrayal in government advertising of
women, ethnic communities, and Aboriginal and Torres Strait Islander
the Auditor-General guideline headed
'Distribution of sensitive material should be controlled' is omitted, and a dot
point is added to the previous guideline which states just that 'distribution
of unsolicited material should be carefully controlled' and that all
advertising material and the manner of its presentation should comply with
relevant law, including broadcasting, media, privacy and electoral law; and
an additional guideline, headed 'Material should
be produced and distributed in an efficient, effective and relevant manner,
with due regard to accountability' is included. This guideline states that
information campaigns should be justified by a cost-benefit analysis and that
the campaign 'should be justified in terms of society's needs, efficiency and
effectiveness, and there should be a clear audit trail regarding decision
The then Deputy Chair of the JCPAA, Mr
David Cox MP,
argued for the incorporation of an objective test for the expenditure of public
money on government information campaigns, to determine the threshold between
party political and appropriate expenditure by government. In particular, he
suggested that no expenditure of public money on mass advertising should occur
until the legislation to implement the relevant policy, program or service has
been passed; and, where a proposed advertising campaign covers a matter that
does not require legislation, an appropriation for the specific purpose of the
campaign must be obtained. He proposed that the only exclusions to these
requirements be where major issues of public health, public safety or public
order arise at short notice.
The JCPAA did not adopt Mr
Cox's proposals in its guidelines.
In addition, another member of the Committee, Mr Petro
Georgiou MP, dissented from components of the JCPAA's guidelines headed
'Material should not be liable to misrepresentation as party political' on the
in a highly combative political system,
materials which are non-partisan are open to misrepresentation as party
the dot points indicating the factors to be used
to determine whether material can be perceived as 'party political' do not
provide a sufficiently clear and objective basis for assessing whether or not
such a perception is valid.
relied on these remarks by Mr Georgiou
to argue against adopting any part of the JCPAA's proposed guidelines. The Committee notes, however, that
neither Mr Georgiou
nor Mr Cox
dissented from the JCPAA's statement of the underlying principles governing the
use of public funds for government information programs. There was therefore
unanimous support from the JCPAA for the principle that 'government information
programs shall not be conducted for party-political purposes'.
The JCPAA recommended that the Government adopt its
guidelines for government advertising. It noted that there were different views
within the Committee over whether the guidelines should be legislated or left
as Ministerial or Cabinet guidelines.
Senate Finance and Public Administration Legislation Committee
In 2002, the F&PA Legislation Committee reported on
its inquiry into four pieces of proposed legislation introduced as either
Private Member's or Senator's Bills. The four pieces of legislation were:
the Government Advertising (Objectivity,
Fairness and Accountability) Bill 2000 introduced into the House of
Representatives by the Hon. Mr Kim Beazley MP;
the Charter of Political Honesty Bill 2000 
introduced into the Senate by Senator Andrew Murray;
the Electoral Amendment (Political Honesty) Bill
2000 introduced into the Senate by Senator Andrew Murray; and
the Auditor of Parliamentary Allowances and
Entitlements Bill 2000 introduced into the Senate by Senator John Faulkner and
into the House of Representatives by the Hon. Mr Kim Beazley MP.
Two of these bills, the Government Advertising
(Objectivity, Fairness and Accountability) Bill 2000 and the Charter of
Political Honesty Bill 2000 , proposed measures to better regulate
government advertising. The measures proposed in both bills drew largely on the
guidelines proposed by the Auditor-General and the JCPAA, but also advocated
enforcement of those guidelines respectively through the courts and through a
committee including the Auditor-General and the Ombudsman.
These proposals were discussed in the F&PA
Legislation Committee's report, which raised a number of concerns about the
enforcement provisions. Largely because of these concerns, the Committee
recommended that the bills not proceed.
Nevertheless, as noted above, the F&PA Legislation Committee
also concluded that there was strong evidence to support the argument that
arrangements for regulating the political content of government advertising
need to be improved 'in the face of public criticism'. The Committee notes that public
criticism has not abated. Indeed, if anything, it has increased.
The Committee therefore recommended that, 'as a minimum',
the 1995 guidelines should be amended to include 'a clear statement of the
fundamental principle: that government information programs should not be, or
be liable to misrepresentation as being, party political'.
The F&PA Legislation Committee acknowledged that it
is difficult to codify the distinction between what is party political and what
is not. However, it noted that its recommended 'fundamental principle' had been
recognised in the United Kingdom's
equivalent guidelines together with elaboration on how that principle is to be
applied. The Committee said that it saw 'no reason why similar material should
not be contained in the Australian guidelines'.
The F&PA Legislation Committee recommended that the
guidelines proposed by the Auditor-General and the JCPAA, in combination with
evidence received by its inquiry, should be used as a basis for developing a
detailed set of standards. It agreed, however, with the Auditor-General that
the development of standards on these matters is 'essentially political', and
that consequently it is for Parliament as a whole to examine, decide and issue
detailed guidelines on what is appropriate.
Accordingly, the Committee's government majority
recommended that the task of developing these standards be referred to a new joint
parliamentary committee. This
recommendation was not acted upon by the government.
Government arguments against revision of 1995 guidelines
In evidence to this Committee, the government mounted
two arguments against the revision of the 1995 guidelines using those proposed
by previous inquiries as a basis.
The first argument, as noted above, was that there is
no need to revise the existing guidelines. That argument in turn relies upon
the claim that there are no 'problems' with government advertising practice
that are not covered by those guidelines.
The Committee finds Senator Abetz's dogged defence of
the sufficiency of these guidelines somewhat undermined by the fact that his
government consistently fails to meet the only measurable requirement they
contain, namely the requirement that 7.5% of expenditure on advertising in
newspapers and on radio be spent on non-English language media. Further, his
insistence that there is nothing 'necessary for accountable, efficient and
cost-effective delivery of information activities' that is not covered fully by the
1995 guidelines is simply not borne out by comparison between them and the
revised guidelines proposed by the Auditor-General and the JCPAA.
For example, in relation to the requirements of
objectivity and impartiality, the 1995 guidelines say that:
All information programs conducted by departments should be as
impartial and as complete as practicable and based on the information needs and
capacities of the target audience. Information programs should be based on
relevant research, and contain feedback and evaluation mechanisms where
possible. Departments should use simple, clear language in all communication
with the public to ensure their messages are easily understood.
The Auditor-General and JCPAA guidelines state:
The following guidelines are suggested to assist in determining
whether the material communicated is presented in an explanatory, fair,
objective and accessible manner:
- Information campaigns should be directed at the
provision of objective, factual and explanatory information. Information should
be presented in an unbiased manner;
- Information should be based on accurate,
verifiable facts, carefully and precisely expressed in conformity with those
facts. No claim or statement should be made which cannot be substantiated.
- The recipient of the information should, to a
practical and reasonable extent, be able to distinguish clearly and easily
between facts on the one hand, and comment, opinion and analysis on the other.
- When making a comparison, the material should
not attempt to mislead the recipient about the situation with which the
comparison is made and it should state explicitly the basis for the comparison.
There is nothing incorrect about the overall statement
of principle given by the 1995 guidelines on this matter. Only someone wishing
to wilfully avoid the requirements of objectivity and impartiality, however,
could claim as Senator Abetz
did that this second set of guidelines 'offers nothing of value in addition to
the 1995 Guidelines'.
The second of Senator Abetz's arguments against
revising the 1995 guidelines is that it is not possible to codify the
distinction between 'government' and 'political' advertising, and that any
attempt to make such distinctions will require public servants to make
essentially political judgements.
In his submission to the Committee, Senator
Abetz made both these points. On the first
issue, he said that the requirement in both the Auditor-General's and the
JCPAA's proposed guidelines that 'material should not be liable to
misrepresentation as party political' is unworkable in a combative political
system. He argued that:
Even seemingly innocuous and bipartisan campaigns could become
the subject of political controversy. For example, doctrinaire pacifist
parliamentarians could claim that something as accepted as 'Defence Force
Recruitment' is 'party political' because it reinforces a view of Australian
defence – ie. armed forces – which is at odds with their own view. Another
seemingly innocuous example is the 'Tough on Drugs' campaign that carries an
overtly anti-marijuana message, despite the fact that there are some
parliamentarians who actively support the decriminalisation and use of that
The Committee notes that Senator Abetz
has confused two separate issues in these remarks. He has confused the question
of whether there may be controversy over the content of certain advertisements
with the question of the reasons for that controversy. He has failed to notice
the distinction between controversy which arises on policy grounds or because of policy
differences, and controversy which arises because of the misuse of taxpayer
funds in the service of essentially political
In other words, Senator Abetz's argument implies that
it is not possible to distinguish between government advertising campaigns that
inform the public of policies or advise of entitlements, whether one endorses
those policies or not, and advertising campaigns that promote the government's
views in a partisan way. This is clearly not the case.
The Committee acknowledges that whether a particular
campaign to advertise a government policy or program avoids 'partisan
promotion' of that policy is a matter of judgement. There may be differences of
opinion on these questions, and no guidelines can provide an absolutely
objective way of drawing the line. However, this does not mean that it is
impossible to make any judgements at all on these issues. Other governments in
other countries do it quite easily.
As was illustrated by the discussion in Chapter 4, it
is clearly possible to distinguish between a campaign such as the WorkChoices
campaign which asserts disputed political opinion as fact and those, such as
the Super Choices or the Keeping the System Fair campaigns, which state the
facts about government policies and the obligations they impose on citizens.
raised a second objection to the 'workability' of any of the proposed
guidelines. He claimed that the adoption of guidelines requiring a judgement on
the 'partisan political' content of advertisements would place public servants
in an invidious position. He said:
if the ANAO/JCPAA recommendations were to be implemented,
officials would be required to certify that each element of any information
campaign could, in no way, be misinterpreted as 'party political', yet that
official would have no objective criteria to support their decision for any
such certification ... Thus, any Government official effectively stakes their
reputation and career on the probability that no MP will criticise, either with
or without justification, that particular advertising campaign.
A similar point was made in the submission from the
Department of the Prime Minister and Cabinet, which spoke about the 'subjectivity
and difficulty' for officials of interpreting whether a particular information
campaign would be 'liable to misrepresentation as "party political"'. The submission continued that:
It would always be difficult for officials to make judgements in
these areas. For example, any advertising to promote understanding of a
government policy could be regarded as not being 'free from partisan
promotion'. In practice, it would be more appropriate to resolve these
interpretations at the Parliamentary and political level.
The Committee considers that these arguments are highly
misleading. As is clear from the previous chapter's discussion of the processes
involved in decision making about government advertising, these judgements are made at the political level.
Officials provide advice and are involved in implementing government approved
advertising campaigns, but it is the Executive itself through the MCGC that
approves every major and 'sensitive' campaign.
It is the members of the Executive, and not officials,
who would therefore be required under the guidelines to make the judgement that
a particular campaign is directed at promoting party political interests or
not. The argument that officials would be placed in an invidious position by
the government's adoption of the guidelines is a complete furphy.
The Committee considers that the guidelines proposed by
the JCPAA, which combine both the Auditor-General's guidelines and the
essential elements of the 1995 guidelines regarding effective communication to
the whole community, provide a comprehensive basis for a set of principles and
guidelines for government advertising. The Committee cannot give credit to a
line of argument that says that every line of those principles and guidelines
has no merit.
The Committee considers, however, that the two sets of
additional remarks made by Mr Cox
and Mr Georgiou
raise points that should also be taken account of in implementing the
First, the Committee considers that no expenditure of
public money for mass media advertising should be undertaken until the
government has obtained passage of the legislation giving it authority to
implement the relevant policy, program or service. Where a proposed public
information or education campaign covers a matter which does not require
legislation, an appropriation for the specific purpose of the campaign must be
obtained. The requirement should not be enforced in situations where major
issues of public health, safety or public order have arisen at short notice.
Second, the Committee considers that the heading of the
guideline which states that 'material should not be liable to misrepresentation
as party political' may give rise to unnecessary debate and controversy. The
heading should read instead that 'material should not be directed at promoting
party political interests'.
The question of what other measures might need to be
taken to give effect in practice to such principles and guidelines is
considered in the next chapter.
The Committee recommends that the government update the
1995 Guidelines on Australian Government Information Activities as a matter of
The Committee recommends that the Government adopt the
Joint Committee of Public Accounts and Audit's draft guidelines for government
advertising, amended as follows:
insert after the third dot point under 'Material
should be relevant to government responsibilities' three additional dot points
- No expenditure of public money should be undertaken on
mass media advertising, telephone canvassing or information services, on-line
services, direct mail or other distribution of unsolicited material until the
government has obtained passage of legislation giving it authority to implement
the policy, program or service described in the public information or education
- Nothing in (a) should be taken to prohibit the
government from seeking a public response to draft legislation or to Green or
White papers. Advertising for public response to draft legislation, however, must
take the form of inviting submissions and formal comment on a published bill or
- Where a proposed public information or education
campaign covers a matter which does not require legislation, an appropriation
for the specific purpose of the public information or education campaign must
- The only exclusions to these requirements are where
major issues of public health, public safety or public order may arise at short
replace the guideline heading 'Material should
not be liable to misrepresentation as party political' with heading 'Material
should not be directed at promoting party political interests'.
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