Western Australia's Auditor General Caroline Spencer has found examples of the state's advertising campaigns to be non-compliant, crossing the line to political messages rather than public information.
The audit, tabled in the state's Parliament, assessed if government ads were accountable, transparent and represents value for money.
While Spencer said in large campaigns followed the advertising rules and important principles that guide public spending, but compliance was not consistent.
"There were examples of non-compliance that demonstrate how campaign advertising can cross the line from appropriately focusing on public information into areas that may be politically advantageous to the government of the day," Spencer said.
"Two notable instances included the use of sentiment polling data in the evaluation of a COVID-19 campaign and a separate campaign targeting the Australian government on decisions about where submarine maintenance should be done."
The audit examined 11 campaigns from five entities delivered between June 2019 and December 2022. Of the 11, five were COVID-19 related campaigns exempted from the Department of the Premier and Cabinet (DPC) application process.
Lack of cost reporting
A similar report done 10 years ago found that the total cost of government campaign advertising was not reported to the Department of Finance (DoF).
Although campaign budgets are approved as part of the government campaign approval process, entities are not required to report on the actual cost of their campaigns, and entities do not consistently evaluate spend against the approved budget or whether the stated campaign objectives have been achieved. Practice in other jurisdictions does.
The spend on each campaign continues to be unknown, not publicly reported and entities do not always conduct campaign evaluations.
"There has been no improvement in this area," Spencer said.
"This limits transparency and makes it harder for Parliament and the public to judge whether advertising campaigns represent value for money."
Panel arrangements
The auditor also identified better use of panel arrangements would offer efficiencies for both entities and agencies
At least nine entities had established panel arrangements for creative services between three to 18 creative agency service providers over five years to 2023.
However, creative agencies the auditor spoke with shared experiences of entities not using panel arrangements as intended, leading to inefficiencies, specifically:
- Entities would appoint all the agencies that had tendered to the panel, in one case 11.
- There was lack of visibility of work allocation for agencies with significant process variation between State government entities.
- Entities would ask all agencies on their panel to pitch for every campaign, resulting in more work and cost for the entity and less chance that agencies would be awarded work resulting in significant out of pocket costs, sometimes up to $60,000 per panel brief pitch
- Some agencies refuse to participate when a panel approach is used, reducing access to creative talent for the State government entities.
Better guidance from DoF on how to use panel arrangements efficiently may have benefits for both State government entities and creative agencies.
Further efficiencies could be available if entities prepared annual plans for their campaign advertising activity and provided that to DPC and the ICRC.
Annual plans are required in other jurisdictions and offer the opportunity to coordinate and combine procurement activity with potential efficiencies and savings. Currently, there is no requirement for entities in WA to develop annual campaign advertising plans.
Next steps
Government campaigns can be a vital tool in providing important information to the public and carry a risk of misuse if campaigns promote the government of the day, which is not an appropriate use of public money.
"This is why there are strict rules that seek to ensure that government advertising campaigns are non-political (apolitical), effective, represent value for money, and are inclusive and accessible," Spencer said.
"This audit is a timely reminder of not only why vitally important principles, often further specified in rules, exist to guide spending of public money on government advertising, but also the important role public servants play in ensuring they are upheld.
"This audit shows how necessary a robust set of principles and rules is in these areas of perennial temptation for governments, and I am pleased that the Department of the Premier and Cabinet has begun work to strengthen that framework.
"Alongside procurement changes the Department of Finance intends to make, I am hopeful that they will help ensure that government advertising campaigns represent an effective and appropriate use of public money."
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