BACKGROUND NOTE, 11 January 2012

The administration of Commonwealth Government advertising

Dr Nicholas Horne
Politics and Public Administration Section

Introduction

Advertising has been an activity of Australian governments ‘since their inception’, and campaign advertising (coordinated advertising activities designed to inform or influence behaviour), in one form or another, has been an element of government advertising in Australia since the 19th century.[1] As the Australian National Audit Office (ANAO) has noted, government advertising ‘is a legitimate element of government communication and information strategies’:[2]

It provides a mechanism for governments to connect directly with citizens, informing them about new and existing government policies, programs or services, providing advice about their obligations, rights and entitlements, and conveying other important information.[3]

The Commonwealth Government is a major advertiser in Australia; over the last decade it has ranked highly in surveys of advertising expenditure conducted by the Nielsen company.[4] The ANAO has also observed that ‘[t]he extent of government advertising activity has been the subject of ongoing debate and scrutiny over many years’. [5]

This Background Note provides an overview of the current administration of Commonwealth Government advertising, together with some historical information. Official figures for campaign advertising expenditure for 1994 to 2011 are also provided, along with figures for non-campaign advertising expenditure for 1994 to 2008.

Government advertising and political advertising

This Background Note does not consider political advertising (for example electoral advertising), which seeks to influence voting at elections and which is arranged and financed by political parties and/or candidates.[6] It is important to note, however, that the use—real or perceived—of publicly-funded government advertising campaigns as de facto political advertising has been a longstanding issue, often in relation to particular campaigns.[7] In a 2005 inquiry report on government advertising, a majority of the Senate Finance and Public Administration References Committee (SFPARC) noted that:

The problem with government advertising arises when … governments use or are perceived to use taxpayer funds to gain political advantage through promoting themselves, rather than to meet the genuine information needs of citizens. Over a number of years, concern has been expressed by members and Senators on all sides of politics that incumbent governments have succumbed to this temptation.[8]

The SFPARC majority took the view that there was evidence that ‘some government advertising campaigns amount to a form of party political advertising by stealth, conducted at taxpayers’ expense’, and made a number of recommendations relating to the adoption of guidelines and the reporting and scrutiny of government advertising.[9] In the years prior to the SFPARC inquiry the Commonwealth Auditor-General and the Joint Committee of Public Accounts and Audit (JCPAA) had both recommended the adoption of guidelines to assist in distinguishing between government advertising and political advertising.[10]

Over the last decade a number of bills have been introduced into the Parliament by non-government parties and parliamentarians seeking to regulate government advertising and prevent its use for political purposes.[11] A common measure in these bills has been the insertion of campaign advertising guidelines into legislation. None of these bills have been enacted; the most recent bills, the Preventing the Misuse of Government Advertising Bill 2010 and the Government Advertising (Accountability) Bill 2011, are currently before the Senate.[12]

The administration of Commonwealth Government advertising

Definitions

The two major categories of government advertising are campaign advertising and non-campaign advertising. The term ‘campaign’ has been broadly defined by the Department of Finance and Deregulation (DoFD) in this context as ‘a planned series of communication activities that share common objectives, target the same audience and have specific timelines and a dedicated budget’.[13]

Campaign advertising is defined by the DoFD as involving ‘paid media placement and is designed to inform, educate, motivate or change behaviour’:[14]

Advertising campaigns inform the community and/or specific target audiences about their rights, entitlements and obligations and may encourage consideration of issues and provide information about the ongoing business activities of government.[15]

Non-campaign advertising is defined by the DoFD as ‘[s]imple, informative advertising that generally appears only once or twice, contains factual statements and typically has a low creative content’.[16] Examples of non-campaign advertising include ‘staff recruitment, public notices, auction and tender notices, and invitations to make submissions or apply for grants’.[17] While recruitment advertising will generally be non-campaign advertising, the DoFD notes that ‘[l]arge-scale recruitment advertising not related to specific job vacancies and with a degree of creative content may be considered an advertising campaign’.[18] An example of this is the large and ongoing Defence Force recruitment campaign.

A third category of government advertising, the information campaign, is distinguished from campaign advertising in that information campaigns do not involve paid media placement.[19]

Agencies (commonly departments) have carriage of the development and implementation of both campaign and non-campaign advertising.

Regulation

There is no legislation that specifically regulates government advertising, although certain overarching statutory requirements can apply to government advertising activities (for example approval requirements for the expenditure of public moneys, and a requirement for broadcasters to include certain identification information after broadcasts that contain ‘political matter’[20]). As noted above, various attempts have been made over the years to bring government advertising within a specific legislative framework.

Information and advertising campaigns

Information and advertising campaigns are governed by a combination of government policy and administrative guidelines and processes. The main regulatory mechanism for campaigns is the current Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies issued in March 2010 (2010 Guidelines). The 2010 Guidelines are the second set of guidelines to be issued since 2008 and the third since the 1980s (see further below).

The 2010 Guidelines underpin information and advertising campaign activities; compliance with the 2010 Guidelines is mandatory for all agencies that are subject to the Financial Management and Accountability Act 1997 (Cth) (FMA Act).[21] Agencies conducting campaigns must also comply with ‘all relevant policies and processes issued and amended from time to time by the Special Minister of State or the Minister for Finance and Deregulation or the agency responsible for such policies’.[22] In addition, the participation of public servants in government advertising is subject to separate, specific guidelines developed in 2007. These guidelines state that:

The Government’s policy is not to use public servants in government advertising unless that role is essential in the communication of an important message in cases where there is a demonstrated public interest or public safety issue and where the involvement of the public servant can lend expertise and credibility, for example, a Chief Medical Officer warning of a pandemic or a security expert assessing a terrorist threat.[23]

Currently the Special Minister of State has overall responsibility for campaign advertising regulation and policy; prior to September 2010 responsibility was shared between the Special Minister of State and the Cabinet Secretary.[24]

Principles

The 2010 Guidelines establish three basic principles for the expenditure of public money on information and advertising campaigns:

•        ‘members of the public have equal rights to access comprehensive information about government policies, programs and services which affect their entitlements, rights and obligations’

•        ‘governments may legitimately use public funds to explain government policies, programs or services, to inform members of the public of their obligations, rights and entitlements, to encourage informed consideration of issues or to change behaviour’, and

•        ‘government campaigns must not be conducted for party political purposes’.[25]

The 2010 Guidelines also specify five further detailed principles for the conduct and presentation of information and advertising campaigns. In essence, these principles seek to ensure that campaigns are: ‘relevant to government responsibilities’; objective; intelligible for audiences; non- party-political; needs- and research/evidence-based; efficient and effective; and compliant with ‘all relevant laws’ and government procurement requirements.[26] One important requirement of the principles is that campaigns should only deal with policies and programmes supported by legislation, parliamentary appropriation or a Cabinet decision ‘intended to be implemented during the current Parliament’.[27] The five principles are excerpted at Appendix A.

Approval, review and certification of proposed campaigns

The 2010 Guidelines envisage that the launch of campaigns will be subject to ministerial approval but do not delineate responsibility for approving other elements of campaigns.[28] Other government publications on campaign advertising indicate that ministers approve both campaign launches and the initial proposals for campaigns.[29] In addition to providing these approvals, ministers have ‘a legitimate interest in the development of campaigns in their portfolios’ and are briefed during campaign development and implementation.[30] The JCPAA has noted some lack of clarity in the recent past regarding the nature of ministerial involvement in campaign development.[31]

Approval for the other elements of campaigns (for example engaging consultants, finalising campaign materials, and placing advertising) is the responsibility of the relevant agency. The DoFD ‘provides advice on campaign development and implementation, including participation on evaluation panels for the selection of consultants’ and also manages the centralised system for advertising placement (see further below).[32]

The 2010 Guidelines require that proposed advertising campaigns valued at $250 000 or more must undergo a review and certification process prior to commencement. For the purposes of the $250 000 threshold, campaign value is ‘the budget for all campaign elements across all financial years’ and excludes only internal agency costs.[33] Proposed information campaigns valued at $250 000 or more are exempt from review and certification but are required to comply with the 2010 Guidelines and with ‘other relevant policies and processes’.[34]

Campaigns requiring review and certification are examined by the Independent Communications Committee (ICC) regarding compliance with the first four of the five detailed principles in the 2010 Guidelines relating to campaign conduct and presentation. Compliance with the fifth principle regarding legal and procurement requirements is examined by agencies. The ICC, established in March 2010, is comprised of contracted consultants appointed by the DoFD Secretary and is supported by a secretariat of DoFD staff.[35] Following ICC/agency review, compliance is certified by the chief executive of the relevant agency. The review and certification process is as follows:

•        the ICC reviews the proposed campaign using a range of materials together with ‘any other information or independent expert advice available’ and reports to the agency chief executive regarding compliance with the first four detailed principles in the 2010 Guidelines. The agency concerned also reports to its chief executive regarding compliance with the fifth principle.

•        after considering the ICC and agency reports, the agency chief executive certifies compliance with the 2010 Guidelines and with ‘relevant government policies’. The relevant minister is provided with the certification and ‘may launch the campaign or approve its launch’.[36]

Agency chief executives are also able to request ICC review of advertising campaigns valued at less than $250 000.[37]

The ICC can examine campaigns throughout their development, but usually exercises its review function before campaign materials are produced and again after the production of materials but before campaign commencement.[38] ICC review reports are published on the DoFD website once campaigns have been launched, and agency chief executive certifications are published on agency websites upon campaign launch.[39]

In addition to reviewing campaigns, the ICC also ‘oversee[s] the operation of the Guidelines to ensure compliance with their integrity and spirit’ and provides additional reporting and proposals for changes to the 2010 Guidelines as needed.[40]

A DoFD flowchart setting out the campaign approval, review and certification process is excerpted at Appendix B.

Exemptions from compliance

Proposed information and advertising campaigns can be exempted from compliance with the 2010 Guidelines by the Special Minister of State ‘on the basis of a national emergency, extreme urgency or other compelling reason’.[41] Exemptions are to be reported to the ICC and to the Parliament.[42] Since 2008 three exemptions have been granted in relation to specific campaigns:

•        a 2009 H1N1 Influenza Public Information campaign was granted an exemption in April 2009 on the basis that ‘a pandemic event, or its lead up, would likely require urgent and widespread public information activities to support public health and safety’.[43] This exemption was from compliance with the previous guidelines in place between 2008 and 2010.

•        advertising activities conducted by the Australian Electoral Commission in July–August 2010 relating to the 2010 Federal election were granted an exemption in August 2009 ‘on the basis that campaigns on electoral matters need to be, and perceived [sic] to be, conducted independently from the government of the day’.[44] This exemption was from compliance with the previous guidelines in place between 2008 and 2010.

•        a 2010 Tax Reform advertising campaign (relating to the Government’s resource taxation policies) was granted an exemption in May 2010 ‘on the basis of urgency and compelling reasons’ in relation to a need to provide public information.[45] This exemption was from compliance with the current 2010 Guidelines.

Whole-of-government procurement requirements

In 2009 the DoFD established a Communications Multi-Use List (CMUL) of advertising and communications providers ‘interested in tendering for work associated with Australian Government advertising and information campaigns’.[46] The CMUL is a whole-of-government procurement mechanism which lists providers in ‘advertising, market research, public relations, communications with Indigenous Australians, and communications with people from non-English speaking backgrounds’.[47] The CMUL is administered by the DoFD and is ‘open to new applicants with experience and expertise’ in these areas; providers wishing to apply for inclusion on the CMUL can apply through the AusTender website.[48]

Agencies subject to the FMA Act must use the CMUL when selecting consultants for work on information and advertising campaigns with an expenditure of more than $250 000. Use of the CMUL is not permitted for information and advertising campaigns with an expenditure of less than $250 000 ‘or for other work not related to a campaign’.[49]

Previous guidelines and the Hawke review

In June 2008 the Rudd Government introduced new guidelines for government advertising. Up to this point government advertising had been regulated by guidelines first introduced in the 1980s and last updated by the Keating Government in 1995.[50] The 2008 Guidelines on campaign advertising by Australian government departments and agencies (2008 Guidelines) represented a significant change from the 1995 guidelines and introduced new requirements, including review by the Commonwealth Auditor-General of information and advertising campaigns valued at over $250 000 and compliance certification by agency chief executives.[51] Some of these requirements were Australian Labor Party election commitments made before the 2007 federal election; the Government also indicated that the 2008 Guidelines were ‘based on those developed by the Auditor-General in 1998’ and ‘refined by the [JCPAA] in 2000’ (see above).[52]

After taking office the Rudd Government also made other changes to the government advertising framework including instituting biannual reporting on campaign advertising expenditure and abolishing the Ministerial Committee on Government Communications (MCGC), which had been established by the Howard Government in 1996. The MCGC, which comprised the Special Minister of State as Chair along with other government members of Parliament and staff, took decisions ‘on all key matters relating to major and sensitive information campaigns (including advertising campaigns) undertaken by Australian Government agencies’.[53] Prior to the MCGC an equivalent body, the Ministerial Committee on Government Information and Advertising, had existed under the Hawke/Keating Governments.[54]

In early 2010 the Rudd Government commissioned a review (foreshadowed in 2009) of the government advertising framework including the 2008 Guidelines.[55] The review, conducted by former departmental secretary Dr Allan Hawke AC, was completed in February 2010 and endorsed the framework and Guidelines as having ‘introduced standards, transparency and a level of rigour which are supported and should be continued’.[56] However, the review also raised ‘significant concerns’ with the framework in relation to ‘governance arrangements, clarity of the Guidelines, the supporting processes, administrative burdens and flexibility of the Guidelines to respond to emerging issues’.[57] With respect to the Auditor-General’s campaign review role, the review found that this ‘[drew] into question the independence of the Auditor-General and potentially creat[ed] conflicts of interest’:[58]

In order to protect its position, the Australian National Audit Office … has had to adopt a highly risk-averse approach, placing a heavy (and unnecessary) bureaucratic and administrative burden on departments. In essence, the role that the Auditor-General has been given has undermined the proper accountabilities of Secretaries for managing their departments and the Auditor-General’s proper place the scheme of things …[59]

The review made several recommendations for change including:

•        simplification and clarification of the 2008 Guidelines and an increase in the campaign value threshold for compliance reviews of proposed campaigns

•        cessation of campaign compliance reviews by the Auditor-General and transfer of the review function to either a new independent committee or the existing interdepartmental committee

•        performance audits by the Auditor-General of ‘at least one campaign per year, or the administration of the campaign advertising framework’

•        the formation of a unit in the Department of the Prime Minister and Cabinet (DPMC) for whole-of-government advice, coordination, and procurement management, and to support the new review committee, and

•        publication of campaign compliance review conclusions and chief executive certifications, twice-yearly reporting to Parliament on campaign expenditure, and quarterly reporting to Cabinet on expenditure and future campaigns.[60]

The Government accepted almost all of the review’s recommendations including revising the 2008 Guidelines and establishing the ICC to undertake campaign compliance review in place of the Auditor-General. The recommendations to increase the campaign value threshold for compliance reviews and to establish a dedicated unit in DPMC were not accepted (the latter because the DoFD was performing the role).[61] The revised (and current) 2010 Guidelines were issued in March 2010.[62]

After completion of the Hawke review the Auditor-General raised concerns with the Special Minister of State regarding the level of consultation during the review and the review’s interpretation of the Auditor-General’s role. The Auditor-General also stated that the involvement of the ANAO in reviewing proposed campaigns had ‘brought rigour and discipline to this aspect of public administration that, in the past, had been problematic to say the least’, and expressed the view that some of the proposed revisions to the 2008 Guidelines recommended by the Hawke review constituted ‘a general softening in the application of requirements on agencies’.[63] In response the Government stated that consultation with the Auditor-General had been a requirement of the review and that the revised 2010 Guidelines did not constitute a softening of requirements:

… rather, the new governance framework aims to allocate responsibilities to those best placed to manage them, while retaining a significant independent review mechanism through the establishment of the Independent Communications Committee.[64]

In May 2010 the Auditor-General indicated that the ANAO will continue to conduct periodic audits of government advertising activities.[65]

Over 2009–11 the JCPAA conducted an inquiry into the role of the Auditor-General in scrutinising advertising campaigns. In its inquiry report the JCPAA expressed the view that it was ‘not an appropriate role’ for the Auditor-General to be ‘involved in the scrutiny of proposed advertising campaigns’ as it ‘blurred the boundary between executive decision-making and audit review’.[66] The JCPAA recommended that:

… any substantial proposed changes to the role of the Auditor-General, in accordance with his standing as an Independent Officer of the Parliament, be first reviewed by the Joint Committee of Public Accounts and Audit.[67]

In its response to the JCPAA’s recommendation the Government stated that it ‘it would not object to the Auditor-General consulting the JCPAA on any significant changes to the role and functions of the Office’, and that:

The functions and powers of the Auditor‐General are specified in the Auditor‐General Act 1997. As with amendments to any Commonwealth Act, any changes to the Auditor‐General’s functions would be subject to the scrutiny of the Parliament as part of the process of enacting amendments. Either House of the Parliament can refer any proposed amendments to the JCPAA for consideration if it so wishes.[68]

The main differences between the 2008 Guidelines and the 2010 Guidelines are set out in Table 1 below. The Hawke review report includes a version of the 2008 Guidelines incorporating the review’s suggested amendments together with a commentary providing reasons for the amendments.[69]

Table 1: Main differences between the 2008 Guidelines and the 2010 Guidelines

2008 Guidelines

2010 Guidelines

Definitions

•        definition of what does not constitute campaign advertising

•        definition of campaign costs with examples

•        overarching definition of ‘campaign’

•        expanded definition of campaign advertising and what does not constitute campaign advertising

•        comprehensive definition of campaign value

Guidelines/Principles

•        five ‘Guidelines for Campaign Advertising’

•        five Guidelines recast as five ‘Information and Advertising Campaign Principles’ with some revision of text

Approval, review and certification requirements

•        compliance review of proposed information and advertising campaigns with an expenditure of more than $250 000 by the Auditor-General; reports provided to ministers

•        ministerial discretion to seek Auditor-General review of proposed information and advertising campaigns with an expenditure of $250 000 or less

•        compliance certification of proposed information and advertising campaigns by agency chief executives

•        compliance review of proposed advertising campaigns valued at $250 000 or more by the ICC and agencies; reports provided to agency chief executives

•        proposed information campaigns valued at $250 000 or more do not require review but must comply with the 2010 Guidelines and with other relevant policies/processes

•        agency chief executives have discretion to seek ICC review of proposed campaigns valued at less than $250 000

•        compliance certification of proposed advertising campaigns valued at $250 000 or more by agency chief executives; certification is not required for information campaigns valued at $250 000 or more

Table 1: Main differences between the 2008 Guidelines and the 2010 Guidelines (cont.)

Exemption from compliance

•        Cabinet Secretary may exempt information and advertising campaigns from compliance ‘on the basis of a national emergency, extreme urgency or other extraordinary reasons the Cabinet Secretary considers appropriate’

•        Auditor-General to be informed of exemptions and reasons for exemptions to be reported to Parliament

•        Special Minister of State may exempt information and advertising campaigns from compliance ‘on the basis of a national emergency, extreme urgency or other compelling reason’

•        ICC to be informed of exemptions and exemptions to be reported to Parliament

Disclosure and reporting

•        Expenditure information for ‘all campaigns commissioned by any agency’ to be made publicly available

•        expenditure information for all FMA Act agency advertising campaigns with an expenditure of more than $250 000 to be reported to Parliament

•        publication of agency chief executives’ certifications and ICC compliance review conclusions

•        publication of research reports for advertising campaigns with an expenditure of $250 000 or more where appropriate

•        publication of advertising campaign details in agency annual reports

Source: Parliamentary Library.

Non-campaign advertising

Non-campaign recruitment advertising in print media is governed by its own set of guidelines, the Guidelines on Non-Campaign Recruitment Advertising (‘Recruitment Advertising Guidelines’), issued in July 2010.[70] The Recruitment Advertising Guidelines apply only to non-campaign recruitment advertising in print media, not to recruitment advertising in other media.[71] Compliance with the Recruitment Advertising Guidelines is mandatory for all agencies subject to the FMA Act; agencies subject to the Commonwealth Authorities and Companies Act 1997 (Cth) are ‘encouraged to comply’.[72] Compliance is also required for agencies that outsource recruitment.[73]

The Recruitment Advertising Guidelines seek to maximise cost-effectiveness and value for money by regulating several aspects of non-campaign recruitment print advertising. Requirements include:

•        use of ‘a single whole-of-government composite recruitment advertisement’ in national and metropolitan newspapers where more than one non-Senior Executive Service (SES) Australian Public Service position is advertised and use of another single composite advertisement for advertising SES positions

•        specified maximum dimensions for advertisements in print media other than national and metropolitan newspapers, and

•        a prohibition on the use of colour in all print media.[74]

The Recruitment Advertising Guidelines also regulate other elements of recruitment advertising in national and metropolitan newspapers including the information to be provided regarding individual positions, the arrangement of individual agency advertisements within the composite advertisements, and whole-of-government branding.[75] In addition, agencies are encouraged to:

•        use composite advertisements when advertising multiple positions in print media other than national and metropolitan newspapers

•        ‘consider the most cost effective advertising option(s) to attract suitable applicants’, and

•        ‘advertise recruitment vacancies on at least one online media forum, in addition to APSjobs, when advertising in the print media’.[76]

Exemptions from compliance

Agency chief executives can exempt advertisements for SES positions from compliance with the single composite advertisement requirement in the Recruitment Advertising Guidelines ‘where special circumstances justify a need for a separate advertisement’. Exemptions for advertisements for non-SES positions are not possible.[77]

Placement of advertising

Placement is the purchase of media (for example print, television, radio, internet) for the running of advertising. Agencies are responsible for arranging the placement of their advertising, and all agencies subject to the FMA Act must place their advertising, both campaign and non-campaign, via the Central Advertising System (CAS), which functions as a single channel for Commonwealth Government advertising placement. The CAS is administered by the DoFD and ‘consolidates government advertising expenditure and optimises media discounts through whole-of-government negotiated media rates’.[78]

Within the CAS the DoFD administers two contracts with media agencies for the placement of advertising: one contract with Universal McCann for the planning and placement of campaign advertising, and another contract with Adcorp Australia for the placement of non-campaign advertising.[79] Both contracts commenced in 2009 and each is for three years with the possibility of extension; the value of the Universal McCann contract is $13.2 million and the value of the Adcorp Australia contract is $0.825 million.[80] All FMA Act agencies are required to place their campaign advertising through Universal McCann and non-campaign advertising through Adcorp Australia.[81]

A number of other entities are able to use the CAS including agencies subject to the Commonwealth Authorities and Companies Act 1997 (Cth), statutory authorities and government business enterprises, organisations which receive Commonwealth funding ‘for advertising or communications purposes’, and the Australian Capital Territory (ACT) and Northern Territory (NT) Governments.[82]

Reporting and scrutiny

Reporting

Information and advertising campaigns

The 2010 Guidelines require reporting to the Parliament on expenditure for ‘all advertising campaigns with expenditure in excess of $250,000 commissioned by FMA Act agencies’.[83] Since 2008, the Government has reported to the Parliament biannually as follows:

•        half-yearly reports for the first half of each financial year (1 July to 31 December) tabled in the following March; these reports detail campaign advertisement placement expenditure for individual campaigns during the period, and

•        full-year reports for the whole financial year tabled in September-October; these reports detail campaign placement expenditure but also provide broader expenditure information for individual campaigns such as spending on advertising consultancies, public relations, market research, direct mail etc.[84]

To date both the half-year and full-year reports have also provided a range of other information including overviews of the campaign advertising framework, historical expenditure, and compliance exemptions. The latest full-year report (for 2010–11) also contains ICC review reports for the period.

The 2010 Guidelines also require agency chief executives to publish ‘research reports for advertising campaigns with expenditure of $250,000 or more’ on agency websites after launch ‘where it is appropriate to do so’, and further specify that agency annual reports will contain information on advertising campaigns conducted by individual agencies.[85]

Non-campaign advertising

The Recruitment Advertising Guidelines contain no requirements regarding reporting of non-campaign advertising expenditure. Figures for non-campaign expenditure for the period 1994–March 2008 are provided below; individual agency annual reports may also provide figures for non-campaign advertising expenditure.[86]

Scrutiny

Commonwealth Government advertising activity (generally campaign advertising) has been the subject of scrutiny by the Parliament, the ANAO, and academic experts over the years. Parliamentary scrutiny has consisted of questions put in the Parliament, committee inquiries, and consideration at Senate estimates hearings. Scrutiny by the ANAO has taken the form of audits of individual campaigns, campaign reviews conducted under the 2008 Guidelines (and associated summary reviews), and audits of advertising administration.

Substantial inquiries and audits conducted since the mid-1990s (including those referred to in this paper) include:

•        JCPAA

–      inquiry into the role of the Auditor-General in scrutinising government advertising campaigns (2011)

–      inquiry into guidelines for government advertising and related matters further to the JCPAA’s review of the ANAO’s audit report on the Community Education and Information Programme (2000)

•        SFPARC—inquiry into government advertising and accountability (2005)

•        ANAO

–      audit of the administration of the campaign advertising framework, compliance with the 2010 Guidelines, and campaign exemptions (current)

–      review of campaign advertising July 2009–March 2010 (2010)

–      review of campaign advertising 2008–09 (2009)

–      audit of government advertising procurement and contracting arrangements to November 2007 (2009)

–      audit of the Community Education and Information Programme relating to the new tax system/GST (1998)

–      audit of Commonwealth Government information and advertising (1995)

•        Hawke review of government advertising arrangements (2010)

As noted above, in 2010 the Auditor-General indicated that the ANAO will continue to conduct periodic audits of government advertising activities.

In regard to non-campaign advertising, in 2010 the Australian Public Service Commission and the DoFD conducted an evaluation of recruitment advertising. The evaluation found that the Recruitment Advertising Guidelines ‘do not appear to have had an impact on the effectiveness of FMA Act agencies’ recruitment advertising’ and that there were ‘no apparent problems with the introduction of the Guidelines’.[87]

Expenditure

Campaign advertising expenditure

Table 2 below provides official figures for total expenditure on campaign advertising placement by financial year since 1994. Figures for 2004–05 onwards are for expenditure by FMA Act agencies only; figures for 1994 to 2004 encompass expenditure by FMA Act agencies, agencies subject to the Commonwealth Authorities and Companies Act 1997 (Cth), and the ACT and NT Governments.

The figures in Table 2 are for advertising placement expenditure only and do not include spending on associated services such as advertising consultancies, market research, public relations, and direct mail. Spending on these associated services is not inconsiderable: between 2008 and 2011 expenditure totalled $125.1m ($38.4m in 2008–09, $39.8m in 2009–10, and $46.9m in 2010–11).[88]

The figures for 2008 to 2011 include ‘[o]ther media’ placement expenditure including placements of less than $250 000 in value. Over this period such other placement expenditure totalled $9.8m ($2.6m in 2008–09, $3.9m in 2009–10, and $3.3m in 2010–11).[89]

Table 2: Campaign advertising placement expenditure 1994–2011

Financial year

Expenditure ($m)

Financial year

Expenditure ($m)

2010–11

$116.9

2001–02

$83.9

2009–10

$114.7

2000–01

$133.2

2008–09

$130.1

1999–2000

$186.8

2007–08

$185.3

1998–99

$54.0

2006–07

$170.1

1997–98

$55.1

2005–06

$120.5

1996–97

$29.4

2004–05

$70.6

1995–96

$47.6

2003–04

$97.8

1994–95

$43.1

2002–03

$51.8

TOTAL 1994–2011

$1 690.9

Source: DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, DoFD, Canberra, September 2011, pp. 34–35, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/full-year-report-2010-11.pdf

Table 3 below lists the 10 largest campaigns by total expenditure (placement and associated services) over the last three financial years (2008–11). Some campaigns (for example the Defence Force Recruiting and Digital Switchover campaigns) are long-term campaigns running over several years. Where campaigns have different stages or closely-related complementary campaigns (for example the National Tobacco campaign, the Measure Up campaign), expenditure for all such campaign elements is aggregated.

Table 3: Ten largest advertising campaigns by expenditure 2008–11

Department/agency

Campaign

Total expenditure ($m)

Dept. of Defence

Defence Force Recruiting campaign

$106.3

DBCDE[90]

Digital Switchover campaign

$48.3

DHA / ANPHA[91]

Australian Better Health Initiative, Measure Up! / Measure Up ‘Swap It, Don’t Stop it’ campaign

$40.8

DHA / ANPHA

National Tobacco campaign

(including Re-invigoration of the National Tobacco Campaign; National Tobacco Campaign—More Targeted Approach; Indigenous Anti-Smoking campaign)

$35.8

DHA

National Binge Drinking campaign

$19.8

DHA

National Illicit Drug Use /

National Drugs campaign

$17.8

DHA

H1N1 Influenza Public Information /

Pandemic H1N1 2009 Vaccination campaign

$14.0

FaHCSIA[92]

Promoting Respectful Relationships (The Line) campaign

$13.4

DHA

Health Reform Plan Communication campaign

$12.4

AEC[93]

Election 2010 campaign

$12.3

Source: Parliamentary Library estimates.[94]

Non-campaign advertising expenditure

Table 4 below provides official figures for total expenditure on non-campaign advertising by financial year from 1994 to March 2008. Figures for 2008 onwards have not yet been published.

Table 4: Non-campaign advertising expenditure 1994–March 2008

Financial year

Expenditure ($m)

Financial year

Expenditure ($m)

2007–March 2008

$53.9

2000–01

$29.9

2006–07

$84.8

1999–2000

$24.1

2005–06

$70.7

1998–99

$19.4

2004–05

$49.7

1997–98

$21.5

2003–04

$45.5

1996–97

$16.9

2002–03

$47.7

1995–96

$23.4

2001–02

$31.1

1994–95

$23.1

TOTAL 1994–Mar 2008

$541.7

Source: J Faulkner (Special Minister of State), L Tanner (Minister for Finance and Deregulation), New advertising guidelines, media release, 2 July 2008, pp. 3–4, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressrel%2F31ZQ6%22

Appendix A: principles for the conduct and presentation of information and advertising campaigns

Source: DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, DoFD, Canberra, March 2010, pp. 3–5, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Guidelines-on-Information-and-Advertising-Campaigns-by-Australian-Government-Departments-and-Agencies-March-2010.pdf

Appendix B: campaign approval, review and certification process

Source: DoFD, Overview of the campaign activity approval and review process for departments and agencies, DoFD, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Overview-of-Campaign-Approval-and-Review-Process.pdf

Glossary

AEC

Australian Electoral Commission

ANAO

Australian National Audit Office

ANPHA

Australian National Preventive Health Agency

APS

Australian Public Service

APSC

Australian Public Service Commission

CAS

Central Advertising System

CMUL

Communications Multi-Use List

DBCDE

Department of Broadband, Communications and the Digital Economy

DHA

Department of Health and Ageing

DoFD

Department of Finance and Deregulation

DPMC

Department of the Prime Minister and Cabinet

FaHCSIA

Department of Families, Housing, Community Services and Indigenous Affairs

FMA Act

Financial Management and Accountability Act 1997 (Cth)

ICC

Independent Communications Committee

JCPAA

Joint Committee of Public Accounts and Audit

MCGC

Ministerial Committee on Government Communications

SES

Senior Executive Service

SFPALC

Senate Finance and Public Administration Legislation Committee

SFPARC

Senate Finance and Public Administration References Committee

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[1].               S Young, ‘A history of government advertising in Australia’, in S Young ed., Government Communication in Australia, Cambridge University Press, Melbourne, 2007, pp. 181–82.

[2].               Australian National Audit Office (ANAO), Campaign advertising review July 2009–March 2010, ANAO, Canberra, 2010, p. 17, viewed 9 January 2012, http://www.anao.gov.au/~/media/Uploads/Documents/2009%2010%20audit%20report%20no%2038.pdf

[3].               Ibid.

[4].               See for example N Shoebridge, ‘Total ad market up a fraction, but retail falls flat’, Australian Financial Review, 26 September 2011, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2F1110554%22; ‘Plenty of pruning among top 25’, Australian Financial Review, 29 March 2010, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2FABAW6%22; ‘Big retailers keep ad budgets healthy’, Australian Financial Review, 30 March 2009, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2FHO5T6%22; R Burbury, ‘Election inspires bumper ad splurge’, Australian Financial Review, 11 November 2004, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2FY1EE6%22; P McIntyre, ‘Federal Government drives ad boom’, Sydney Morning Herald, 11 November 2004, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2F88EE6%22; B O’Riordan, ‘Coles tops advertising big spender list’, Australian Financial Review, 16 December 2002, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2FG7586%22; ‘Govt top ad buyer in 2001: survey’, Canberra Times, 27 February 2002, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2FM8066%22

[5].               ANAO, Campaign advertising review July 2009–March 2010, op. cit., p. 17.

[6].               Electoral advertising can be indirectly financed by public funds due to the Commonwealth election funding scheme which was introduced in 1984 to ‘provid[e] political parties and candidates with adequate funding to contest elections, and reduc[e] their reliance on donations and other private sources of funding’: Australian Government, Electoral reform green paper: donations, funding and expenditure, Australian Government, Canberra, December 2008, p. 58, viewed 9 January 2012, http://www.dpmc.gov.au/consultation/elect_reform/docs/electoral_reform_green_paper.pdf. Under the scheme (set out in the Commonwealth Electoral Act 1918), political parties are eligible for public funding after federal elections at an indexed per-vote rate in respect of endorsed candidates or Senate groups who receive at least four per cent of first preference votes (unendorsed candidates and Senate groups are also eligible for funding). For the 2010 election total public funding for all parties and candidates was $53.163 million: Australian Electoral Commission (AEC), Final 2010 federal election payment to political parties and candidates, media release, 13 October 2010, viewed 9 January 2012, http://www.aec.gov.au/About_AEC/Media_releases/e2010/13-10.htm

[7].               Examples of individual campaigns that have attracted debate include the Working Nation campaign (1995), the New Tax System campaign (1998–2000), the Workplace Relations Reform (WorkChoices) campaign (2005), and the resource taxation Tax Reform campaign (2010). The legality of government expenditure on the 2005 Workplace Relations Reform campaign was unsuccessfully challenged in the High Court of Australia: see Combet v Commonwealth [2005] HCA 61, [2005] 224 CLR 494.

[8].               Senate Finance and Public Administration References Committee (SFPARC), Government advertising and accountability, SFPARC, Canberra, December 2005, p. 8, viewed 9 January 2012, http://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Finance_and_Public_Administration/Completed_inquiries/2004-07/govtadvertising/report/index. The issue has also been the subject of academic discussion; see for example M Sawer, N Abjorensen, P Larkin, Australia: the state of democracy, The Federation Press, Sydney, 2009, pp. 188–90; J Sinclair, S Younane, ‘Government advertising as public communication: cases, issues and effects’, in S Young ed., Government communication in Australia, op. cit., pp. 204–26; S Young, ‘The regulation of government advertising in Australia: the politicisation of a public policy issue’, The Australian Journal of Public Administration, vol. 66, no. 4, 2007, pp. 438–52, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22library%2Fjrnart%2FABCP6%22;
J–C Tham, S Young, Political finance in Australia: a skewed and secret system, Australian National University (ANU), Canberra, 2006, pp. 74–89, 129–32, viewed 9 January 2012, http://democratic.audit.anu.edu.au/papers/focussed_audits/20061121_youngthamfin.pdf; G Orr, ‘Government advertising: informational or self-promotional?’, ANU, Canberra, March 2006, pp. 1–25, viewed 9 January 2012, http://democratic.audit.anu.edu.au/papers/20060320_fin_orr.pdf; S Young, The persuaders: inside the hidden machine of political advertising, Pluto Press, Melbourne, 2004, pp. 122–29.

[9].               SFPARC, Government advertising and accountability, op. cit., pp. 30, xxiii–xxvi. The majority report was dissented from by (then) government senators in a separate minority report (see pp. 107–12).

[10].               ANAO, Taxation reform: community education and information programme, ANAO, Canberra, October 1998, pp. 30, 57–60, viewed 9 January 2012, http://www.anao.gov.au/~/media/Uploads/Documents/1998%2099_audit_report_12.pdf; Joint Committee of Public Accounts and Audit (JCPAA), Report 377: guidelines for government advertising, JCPAA, Canberra, September 2000, pp. 2–7, viewed 9 January 2012, http://www.aph.gov.au/house/committee/jcpaa/CEIP/contents.htm

[11].               For example the Charter of Political Honesty Bill 2000; the Government Advertising (Objectivity, Fairness and Accountability) Bill 2001 (an earlier version had been introduced in 2000); the Government Advertising (Prohibiting use of taxpayers’ money on party political advertising) Bill 2005; the Preventing the Misuse of Government Advertising Bill 2010; and the Government Advertising (Accountability) Bill 2011. These Bills, and associated documentation, can be accessed at:

              Charter of Political Honesty Bill 2000, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fbillhome%2Fs269%22;

              Government Advertising (Objectivity, Fairness and Accountability) Bill 2001, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fbillhome%2Fr1342%22;

              Government Advertising (Prohibiting use of taxpayers’ money on party political advertising) Bill 2005, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fbillhome%2Fr2424%22;

              Preventing the Misuse of Government Advertising Bill 2010, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fbillhome%2Fs786%22;

              Government Advertising (Accountability) Bill 2011, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22legislation%2Fbillhome%2Fs836%22

[12].               The Preventing the Misuse of Government Advertising Bill 2010 was originally introduced in the 42nd Parliament and was reintroduced in the 43rd Parliament by Senator Bob Brown in the Senate on 29 September 2010. In June 2010 the Senate Finance and Public Administration Legislation Committee (SFPALC) conducted an inquiry into the original Bill. A majority of the SFPALC recommended that the Bill ‘not proceed’; Opposition SFPALC members, in a separate report, also indicated that they did not support the Bill (Senator Brown dissented from the majority report): SFPALC, Preventing the Misuse of Government Advertising Bill 2010, SFPALC, Canberra, June 2010, pp. 20, 24, 25–26, viewed 9 January 2012, http://www.aph.gov.au/Senate/committee/fapa_ctte/govt_advert_leg/report/report.pdf. The Government Advertising (Accountability) Bill 2011 was introduced in the Senate on 21 June 2011 by Senator Nick Xenophon and was referred by the Senate to the SFPALC for inquiry and report in July 2011. In September 2011 a majority of the SFPALC recommended that ‘the bill not be passed’. Opposition members agreed with this recommendation in a separate report and Senator Xenophon dissented from the majority report: SFPALC, Government Advertising (Accountability) Bill 2011, SFPALC, Canberra, September 2011, pp. 13, 18–20, viewed 9 January 2012, http://www.aph.gov.au/Senate/committee/fapa_ctte/govt_advert_accountability_leg/report/report.pdf

[13].               Department of Finance and Deregulation (DoFD), Guidelines on information and advertising campaigns by Australian government departments and agencies, DoFD, Canberra, March 2010, p. 1, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Guidelines-on-Information-and-Advertising-Campaigns-by-Australian-Government-Departments-and-Agencies-March-2010.pdf

[14].               Ibid., p. 2.

[15].               DoFD, ‘Campaign advertising’, DoFD website, viewed 9 January 2012, http://www.finance.gov.au/advertising/campaign-advertising.html

[16].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 2.

[17].               DoFD, ‘Non-campaign advertising’, DoFD website, viewed 9 January 2012, http://www.finance.gov.au/advertising/non-campaign-advertising.html

[18].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 2.

[19].               Ibid., p. 1.

[20].               For an example of the former see Regulation 9 of the Financial Management and Accountability Regulations 1997; for the latter see Schedule 2, Clauses 1 and 4 of the Broadcasting Services Act 1992 (Cth) (‘political matter’ is defined in Clause 1 as ‘any political matter, including the policy launch of a political party’). Political advertising is subject to a degree of specific statutory regulation; the Commonwealth Electoral Act 1918, for example, imposes authorisation requirements for electoral advertisements and prohibits misleading and deceptive electoral advertising during a specific period prior to elections. The Broadcasting Services Act 1992 (Cth) also imposes requirements on broadcasters in relation to electoral advertising.

[21].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 1. Over 100 agencies are subject to the FMA Act including the Departments of State.

[22].               Ibid., p. 1.

[23].               Australian Public Service Commission (APSC), ‘Guidelines on the involvement of public servants in public information and awareness initiatives’, APSC website, viewed 9 January 2012, http://www.apsc.gov.au/publications07/publicinformation.htm

[24].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, DoFD, Canberra, September 2011, p. 2, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/full-year-report-2010-11.pdf

[25].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 1.

[26].               Ibid., pp. 3–5.

[27].               Ibid., p. 3.

[28].               Ibid., p. 2.

[29].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit.; DoFD, Overview of the campaign activity approval and review process for departments and agencies, DoFD, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Overview-of-Campaign-Approval-and-Review-Process.pdf

[30].               Ibid.; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., pp. 2, 5.

[31].               Joint Committee of Public Accounts and Audit (JCPAA), Report 421: the role of the Auditor-General in scrutinising government advertising, JCPAA, Canberra, March 2011, pp. 37–39, viewed 9 January 2012, http://www.aph.gov.au/house/committee/jcpaa/govtad/report/fullreport.pdf

[32].               DoFD, Overview of the campaign activity approval and review process for departments and agencies, op. cit.

[33].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 2.

[34].               Ibid., p. 3.

[35].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., pp. 3, 46; Senate Finance and Public Administration Legislation Committee, Answers to Questions on notice, Finance and Deregulation Portfolio, Budget Estimates 2010–11, 27 May 2010, Question F51, viewed 9 January 2012, http://www.aph.gov.au/Senate/committee/fapa_ctte/estimates/bud_1011/Finance/qon/F51.pdf; J Grant, D Tune, ‘Senate Finance and Public Administration Legislation Committee: budget estimates’, Senate, Debates, 27 May 2010, pp. 5, 7, 23, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22committees%2Festimate%2F13012%2F0001%22. Currently the ICC has three members: Dr Allan Hawke AC (Chair), Ms Helen Williams AO, and Ms Anthea Tinney PSM.

[36].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., pp. 2–3, 5; DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 2. See also S Helgeby, ‘Senate Finance and Public Administration Legislation Committee: additional estimates’, Senate, Debates, 22 February 2011, p. 17, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22committees%2Festimate%2F13571%2F0003%22

[37].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 2.

[38].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 3; DoFD, Overview of the campaign activity approval and review process for departments and agencies, op. cit. See also J Grant, ‘Senate Finance and Public Administration Legislation Committee: additional estimates’, Senate, Debates, 22 February 2011, op. cit., pp. 16, 25.

[39].               For ICC review reports to date see DoFD, ‘Review reports by the independent communications committee on government advertising campaigns’, DoFD website, viewed 9 January 2012, http://www.finance.gov.au/advertising/independent-communications-committee.html. For examples of agency chief executive certification see Department of Health and Ageing (DHA), ‘Campaigns and related websites: campaign certification statements’, DHA website, viewed 9 January 2012, http://www.health.gov.au/internet/main/publishing.nsf/Content/campaign_certification_statements-lp; Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA), ‘Certifications: chief executive certification for government advertising campaigns’, FaHCSIA website, viewed 9 January 2012, http://www.fahcsia.gov.au/about/policieslegislation/certification/Pages/default.aspx

[40].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 3.

[41].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 1.

[42].               Ibid.

[43].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2008–09, DoFD, Canberra, September 2009, p. 12, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Full_year_report_2008-09.pdf. The exemption was tabled in the Senate on 11 August 2009 (received by the Senate 29 June 2009): S Ryan, ‘Documents: tabling’, Senate, Debates, 11 August 2009, p. 4476, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22chamber%2Fhansards%2F2009-08-11%2F0098%22

[44].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2009–10, DoFD, Canberra, October 2010, p. 9, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Full_year_report_2009-10.pdf. The exemption was tabled in the Senate on 17 September 2009: S Sherry (Assistant Treasurer), ‘Ministerial statements: Australian Electoral Commission public information campaigns’, Senate, Debates, 17 September 2009, p. 6904, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22chamber%2Fhansards%2F2009-09-17%2F0207%22

[45].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2009–10, op. cit.; J Ludwig (Special Minister of State, Cabinet Secretary), Approval of exemption from guidelines on information and advertising campaigns by Australian government departments and agencies, media release, 28 May 2010, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressrel%2F06VW6%22. The exemption was tabled in the Senate on 15 June 2010 (received by the Senate 28 May 2010 and 3 June 2010): G Barnett, ‘Documents: tabling’, Senate, Debates, 15 June 2010, pp. 3267–68, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22chamber%2Fhansards%2F2010-06-15%2F0114%22

[46].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 4.

[47].               DoFD, 2009–10 Annual report, DoFD, Canberra, 2010, p. 51, viewed 9 January 2012, http://www.finance.gov.au/publications/annual-reports/annualreport09-10/pdf/ar-outcome2.pdf

[48].               DoFD, ‘Communications multi-use list’, DoFD website, viewed 9 January 2012, http://www.finance.gov.au/advertising/communications-mul.html

[49].               Ibid.

[50].               S Young, ‘The regulation of government advertising in Australia: the politicisation of a public policy issue’, op. cit., p. 439. The 1995 Guidelines for Australian government information activities: principles and procedures are available at Appendix F to A Hawke, Independent review of government advertising arrangements, DoFD, Canberra, February 2010, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Independent-Review-of-Government-Advertising-Arrangements.pdf

[51].               The 2008 Guidelines on campaign advertising by Australian government departments and agencies are available at Appendix A to DoFD, Campaign advertising by Australian government departments and agencies: full year report 2009–10, op. cit., pp. 43–48.

[52].               K Rudd, P Wong, Federal Labor to lift standards on taxpayer funded advertising—$1.7 billion spent by Howard Government, media release, 19 May 2007, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressrel%2F5J4N6%22; Australian Labor Party (ALP), Cleaning up government—background information, ALP, n.p., August 2007, pp. 2–3, viewed 9 January 2012, http://pandora.nla.gov.au/pan/22093/20071022-1405/www.alp.org.au/download/now/cleaning_up_government.pdf; J Faulkner (Special Minister of State), L Tanner (Minister for Finance and Deregulation), New advertising guidelines, media release, 2 July 2008, p. 1, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressrel%2F31ZQ6%22

[53].               ANAO, Campaign advertising review 2008–09, ANAO, Canberra, 2009, p. 16, viewed 9 January 2012, http://www.anao.gov.au/~/media/Uploads/Documents/07092009%2010_audit_report_2.pdf

[54].               The Ministerial Committee on Government Information and Advertising was established in 1982 or 1983. See ANAO, The administration of contracting arrangements in relation to government advertising to November 2007, ANAO, Canberra, 2009, p. 26, viewed 9 January 2012, http://www.anao.gov.au/~/media/Uploads/Documents/2008%2009_audit_report_24.pdf

[55].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2008–09, op. cit., p. iv.

[56].               Hawke, Independent review of government advertising arrangements, op. cit., p. 21.

[57].               Ibid., p. 3.

[58].               Ibid.

[59].               Ibid.

[60].               Ibid., pp. 22–28.

[61].               Australian Government, Summary of Hawke recommendations and government response, Australian Government, DoFD, n.d., pp. 1–3, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Hawke-recommendations-and-Government-response.pdf

[62].               L Tanner (Minister for Finance and Deregulation), J Ludwig (Special Minister of State), Half year report on government advertising campaigns, media release, 31 March 2010, p. 2, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressrel%2F6VNW6%22

[63].               I McPhee, ‘Letter to Senator the Hon Joe Ludwig, Special Minister of State’, 29 March 2010, DoFD, pp. 2–3, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Attachment-A-Auditor-General-to-SMOS.pdf. After the 2010 Guidelines were released some of the revisions also received some criticism in the media; see P van Onselen, ‘The price of political expediency’, Australian, 1 June 2010, viewed 9 January 2012, http://parlinfo.aph.gov.au/parlInfo/search/display/display.w3p;query=Id%3A%22media%2Fpressclp%2FATVW6%22

[64].               D Tune, ‘Letter to Mr Ian McPhee PSM, Auditor-General’, 31 March 2010, pp. 1–2, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Ian-McPhee.pdf

[65].               ANAO, Campaign advertising review July 2009–March 2010, op. cit., p. 7.

[66].               JCPAA, Report 421: the role of the Auditor-General in scrutinising government advertising, op. cit., p. 49.

[67].               Ibid.

[68].               Australian Government, Government response: JCPAA report 421, JCPAA, Canberra, 2011, viewed 9 January 2012, http://www.aph.gov.au/house/committee/jcpaa/govtad/govtresp.pdf

[69].               A Hawke, Independent review of government advertising arrangements, op. cit., Appendix B.

[70].               The introduction of recruitment advertising guidelines was announced in the 2009–10 Budget: Australian Government, Budget measures: budget paper no. 2: 2009–10, Commonwealth of Australia, Canberra, 2009, p. 251, viewed 9 January 2012, http://cache.treasury.gov.au/budget/2009-10/content/bp2/download/bp2_Consolidated.pdf. A previous iteration of the recruitment advertising guidelines was issued in July 2009.

[71].               DoFD, Guidelines on non-campaign recruitment advertising, DoFD, Canberra, July 2010, pp. 2, 3, viewed 9 January 2012, http://www.finance.gov.au/advertising/docs/Guidelines-On-Recruitment-Advertising.pdf

[72].               Ibid., p. 3.

[73].               Ibid., p. 5.

[74].               Ibid., pp. 5–7 (the national and metropolitan newspapers are specified on p. 6).

[75].               Ibid., pp. 6–7.

[76].               Ibid., pp. 4, 7.

[77].               Ibid., p. 3.

[78].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 4.

[79].               Ibid.; DoFD, ‘Central advertising system’, DoFD website, viewed 9 January 2012, http://www.finance.gov.au/advertising/cas.html

[80].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2008–09, op. cit., pp. 10, 12–13 (Universal McCann was reappointed); DoFD, 2009–10 Annual report, op. cit., p. 51; DoFD, Financial year 2010/11 Senate order on departmental and agency contracts listing relating to the period 1 July 2010 to 30 June 2011, DoFD, Canberra, 2011, pp. 2, 17, viewed 9 January 2012, http://www.finance.gov.au/publications/contract-in-finance/docs/Financial_year_2010-11_listing_of_department_contracts.pdf

[81].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 4; DoFD, ‘Campaign advertising’, op. cit.; DoFD, ‘Non-campaign advertising’, op. cit. The Recruitment Advertising Guidelines provide an overview of the process of placing recruitment advertising: see pp. 8–10.

[82].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 4.

[83].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 3.

[84].               All half-yearly and full-year reports to date are available on the DoFD website, viewed 9 January 2012, http://www.finance.gov.au/advertising/campaign-advertising-reports.html

[85].               DoFD, Guidelines on information and advertising campaigns by Australian government departments and agencies, op. cit., p. 3. For some examples of published agency campaign research reports see DHA, ‘Campaigns and related websites: campaign research reports’, DHA website, viewed 9 January 2012, http://www.health.gov.au/internet/main/publishing.nsf/Content/campaign_research_reports

[86].               For example the Department of the Treasury spent $22 462 on recruitment advertising in 2010–11: Department of the Treasury, Annual report 2010–11, Department of the Treasury, Canberra, 2011, p. 278, viewed 9 January 2012, http://www.treasury.gov.au/documents/2209/PDF/Treasury_AR_2010-11.pdf

[87].               Australian Public Service Commission (APSC), Evaluation of recruitment advertising: agency feedback—survey 3 final report, APSC, Canberra, 2011, p. 4, viewed 9 January 2012, http://www.apsc.gov.au/advertisingsurvey/agencyreportsurvey3-2Jun11.docx

[88].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2008–09, op. cit., pp. 20–44; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2009–10, op. cit., pp. 16–37; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., pp. 12–31.

[89].               DoFD, Campaign advertising by Australian government departments and agencies: full year report 2008–09, op. cit., p. 18; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2009–10, op. cit., p. 14; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., p. 10.

[90].               Department of Broadband, Communications and the Digital Economy.

[91].               DHA is the Department of Health and Ageing; ANPHA is the Australian National Preventive Health Agency.

[92].               Department of Families, Housing, Community Services and Indigenous Affairs.

[93].               Australian Electoral Commission.

[94].               Compiled from DoFD, Campaign advertising by Australian government departments and agencies: full year report 2008–09, op. cit., pp. 27–43; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2009–10, op. cit., pp. 21–36; DoFD, Campaign advertising by Australian government departments and agencies: full year report 2010–11, op. cit., pp. 13–27.