DPC’s three member Independent Communications Review Committee is made up of senior DPC employees as well as the Director of Government Media from the Office of the Premier. In one of the five campaigns we reviewed the Director participated in campaign design and development; and then, later as part of the ICRC, gave approval for the campaign to proceed. This is a conflict of interest that diminishes the independence and credibility of the ICRC.
Changes requested by DPC a week before the scheduled launch date of a campaign resulted in the agency incurring a $133 000 cancellation fee (23 per cent of the approved budget). This was done to avoid having two high profile campaigns airing in the Perth metropolitan region at the same time.
All the campaigns we looked at complied with the Policy requirement not to advertise during the caretaker period at least one month before an election. Specifically, it required that government advertising be deferred during this period, except for advertising relating to public inquiries, services provided by agencies or community services announcements.
Media buying for advertising campaigns increased in the year leading up to the 2005 and 2013 State elections. The buying increased by approximately 43 per cent ($6 million) in 2005 and approximately 10 per cent ($1.8 million) before the 2013 election. Although this may be justified, it contributes to the perception that government advertising may be promoting the incumbent government. In contrast, media buying fell ahead of the 2008 election.
DPC did not evaluate outcomes of completed campaigns. Although all the completed campaigns we reviewed were evaluated, the agencies did not report the results to DPC because it was not a condition of campaign approval. This information could be used by DPC to inform future campaign approvals and its Policy.
DPC does not know the total amount spent by government on campaign advertising. For the five campaigns in our sample, DPC was only aware of about 70 per cent of the cost incurred by agencies. While it knew the cost of buying slots on television or radio stations, or printed advertisements, it did not know the cost of developing campaigns. Not having this information prevents DPC from making a judgment about the value for money of campaigns, and limits its ability to publicly report the cost of government advertising.
Campaigns generally complied with the Policy, but DPC did not identify or manage six breaches in the planning and implementation of campaigns. Failure to address breaches undermines the government advertising Policy and guidelines. Breaches included bypassing of DPC’s approval process by one agency, and non-compliance with approval conditions. Specifically:
One agency with frequent advertising requirements initiated and developed campaigns without submitting applications to DPC for approval. In 2012-13 the agency spent approximately $8 million in purchasing media through the CUA. DPC was aware of the agency’s non-compliance with the Policy but did not ensure the agency complied or sought exemption.
Another agency did not inform DPC that it booked an additional campaign worth $249 000 under an already approved booking number. DPC was unaware of these changes because the approved campaign application lacked sufficient documentation and description of the activities to be delivered.
The monitoring by agencies of charges for creative work could be improved. Specifically invoices submitted by the creative advertising companies to two agencies did not detail the time spent on activities and the agreed charge rates. This meant that the agencies could not ensure that the charged rates were correct as is required under Treasurer’s Instruction 304 (TI 304).