Oversight of Government of Canada advertising: Standing Committee on Public Accounts—February 23, 2021
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Memorandum to the Deputy Minister
In this section
For decision
CCM: 158792
Assistant Deputy Minister: James Stott, 819-420-5499
Security: Protected A
Subject: Deputy Minister (DM) draft report for the Office of the Auditor General's (OAG) Audit of the Oversight of Government of Canada Advertising
Report 4: Oversight of Government of Canada advertising
Summary
This memorandum is to request your approval of the department's management response to and feedback on the above-mentioned audit.
The audit presents one recommendation for Public Services and Procurement Canada (PSPC) with which the department agrees.
In terms of feedback on the report, the audit is factual, though several clarifications are required to properly characterize PSPC's role and responsibilities with regards to advertising oversight.
Time frame
A decision is requested by March 22, 2019, as per the deadline set by the OAG.
Background
The OAG notified PSPC on January 26, 2018 that it would be conducting an audit of the Oversight of Government of Canada Advertising.
The objective of the audit was to determine whether Treasury Board of Canada Secretariat (TBS) and PSPC provided adequate oversight to ensure that Government of Canada advertising is non-partisan. The OAG examined whether the review processes were adequately designed, implemented, operated, and monitored to ensure politically neutral government advertising.
The federal entities included in the audit's scope were TBS and PSPC.
The audit's scope spanned from October 2015 until June 2018. It is set to be tabled in May 2019.
Issue
The OAG has provided the department with the DM draft report, which your office has received.
The audit recommends that PSPC provide clear direction and training to staff regarding non-partisan reviews. The department accepts this recommendation and the proposed management response is presented in Annex A (part I).
In providing the DM draft report, the OAG has requested the department's agreement that the report presents audit findings that are factually based.
Generally, while the report is factually based, clarification is required regarding PSPC's roles and responsibilities.
Specifically, the report suggests that campaigns with budgets less than $500,000 are required to be reviewed and approved by PSPC. However, this is not the case as the reviews conducted by PSPC for compliance with legislation and regulations are not mandatory and as such PSPC is not responsible for approving advertising campaigns.
Lastly, the report suggests that the department provided no guidance to its employees on how to conduct the review of campaigns. Although the department does not currently have manuals to train employees on this topic, it is important to note that PSPC provided its communications advisors with informal direction and guidance.
A detailed explanation of these comments as well as PSPC's suggested changes have been provided in the attached Annex A (Part II).
Consultations
The Receiver General and Pension Branch (RGPB), as well as the Office of the Chief Audit Executive were consulted on the department's response to the OAG's DM draft report.
Next steps
The department's management response and comments, will be forwarded to the OAG upon your approval.
Recommendation
It is recommended that you sign the attached response letter (Annex A) to the OAG, which will accompany our comments and management response to the recommendations, by March 22, 2019, as per the deadline set by the OAG.
James Stott
Assistant Deputy Minister
Policy, Planning and Communications Branch
I agree, Bill Matthews
I disagree, Bill Matthews
Attachment:
- Annex A: Response letter to the OAG with enclosures
Carbon copy (cc):
- Mr. Michael Vandergrift, Associate Deputy Minister, PSPC
- Mr. Jean-Pierre Blais, Assistant Deputy Minister, RGPB
- Ms. Linda Anglin, Chief Audit Executive, Office of Chief Audit Executive
Annex A: Response letter to the Office of the Auditor General with enclosures
Ms. Michelle Salvail
Principal Office of the Auditor General of Canada
240 Sparks Street
Ottawa, Ontario K1A 0G6
Dear Ms. Salvail:
This is further to the letter of March 8, 2019, regarding the Deputy Minister draft report for the performance audit of the oversight of Government of Canada advertising, which will be included in the 2019 spring reports of the Auditor General of Canada.
In my capacity as the Deputy Minister of Public Services and Procurement, I have reviewed the Deputy Minister draft report and can confirm that it is factually accurate. However, clarification is required related to Public Services and Procurement Canada's roles and responsibilities with regard to the oversight of Government of Canada advertising. Specifically, the report suggests that campaigns with budgets less than $500,000 are required to be reviewed and approved by PSPC. However, this is not the case as the reviews conducted by PSPC for compliance with legislation and regulations are not mandatory and as such PSPC is not responsible for approving advertising campaigns.
Please find enclosed our management response to the audit recommendation, along with the list of our comments and suggestions for your consideration.
Should you require additional information, please contact Rachel Lagacé, External Oversight Liaison, at 873-469-3625.
Yours sincerely,
Bill Matthews
Deputy Minister
Enclosures
cc:
- Colette Montpetit, Audit Director, Office of the Auditor General of Canada
- Michael Vandergrift, Associate Deputy Minister, PSPC
- James Stott, Assistant Deputy Minister, Policy, Planning and Communications Branch, PSPC
- Jean-Pierre Blais, Assistant Deputy Minister, RGPB, PSPC
- Linda Anglin, Chief Audit Executive, Office of the Chief Audit Executive, PSPC
Public Services and Procurement Canada management response to the Office of the Auditor General recommendations
Audit of the oversight of Government of Canada Advertising
Recommendation (Paragraph 53): PSPC should provide clear direction and training to communications advisors on how to conduct their reviews, including documenting the rational for their assessments of all non-partisanship criteria.
PSPC response: Agreed. PSPC will create/update training materials and checklists for advisors to ensure that all legislative and policy requirements related to Government of Canada advertising (including non-partisanship, federal identity program, official languages) are applied in a consistent and complete fashion. This is expected to be completed by December 2019.
Public Services and Procurement Canada's comments on the Office of the Auditor General's Deputy Minister draft of Oversight of Government of Canada Advertising
Instructions:
- Do not duplicate text from the OAG/commissioner environment and sustainable development (CESD)'s document. Only refer to the section in the document to which your comment pertains
- Comments should be clear and concise. Include evidence to support comments where applicable. If the evidence has previously been provided to OAG/CESD, please provide it again
- Suggested changes should be specific, concrete and aim to create a balanced and factually accurate report
Please ensure to accurately portray PSPC's roles and responsibilities throughout the report. Specifically:
- According to the Directive on Management of Communications (8.2.1)—"PSPC is responsible for providing advisory services and technical advice with respect to legislative and policy requirements for advertising"
- In the Terms of reference: Advertising Standards Canada Review of Non-Partisan Advertising for the Government of Canada—"PSPC is responsible for facilitating the review process between government departments and Advertising Standards Canada (ASC)" (for mandatory review of campaigns with budgets more than $500K)
- There is no reference for PSPC to conduct any review for non- partisan (for any size campaign). We undertake reviews for compliance with legislation and regulations for a number of things including non-compliance, federal identity program and official languages
- The mandatory review for campaigns over $500K undertaken by ASC is not the same type of review that is done by PSPC for campaigns under $500K. PSPC provides advisory services and technical advice on various policies and legislation including non-partisan, official languages and federal identity
| Section reference | Comments (please attach supporting evidence where applicable) | Suggested change |
|---|---|---|
| Paragraph 2 | 65% of the $39.2 million was spent on digital, including the percentage itself provides a more accurate picture of the situation. | …65% of it was spent on digital advertising… |
| Paragraph 5 | Worded as it is gives the impression that the mandatory review for campaigns over $500K undertaken by ASC is the same type of review that is done by PSPC for campaigns under $500K. As we said previously, we provide advisory services and technical advice on various policies and legislation including non-partisan, official languages and federal identity. | Advertising campaigns with budgets greater than $500,000 are required to undergo a mandatory review by Advertising Standards Canada, while those with budgets less than $500,000 can be reviewed by PSPC. |
| Paragraph 10 | The information is incomplete, according to the Terms of reference: Advertising Standards Canada review of non-partisan advertising, Government of Canada departments must "submit all advertising campaigns with budgets greater than $500,000 for mandatory review". | They must submit their advertising campaigns, with budgets greater than $500,000, for review to ensure compliance with non-partisan requirements. |
| Paragraph 28 | As written, the text gives the reader the impression that digital advertising media is chosen because it is less expensive, and therefore entities would use digital media rather that other types of media as to avoid submitting campaigns to ASC. In fact, media is chosen based on which is the best one to reach the audiences in order to achieve campaign objectives. | ...If this is the case it could mean that there will be a decrease in the number... |
| Paragraph 31, b | Government priorities are laid out in the Speech from the Throne and the budget—climate change is one such priority. Government priorities are the subject of advertising and relevant departments work with Privy Council Office (PCO) to develop the annual advertising plan to support government priorities. It is not for the non-partisan oversight process to determine what is political, it is for the process to ensure that what is advertised is consistent with the non-partisan definition. | Given that the main premise of this paragraph is inaccurate, we recommend removing it completely. |
| Exhibit 2 | PSPC is not responsible for approving creatives. PSPC is only responsible for reviewing creatives and providing advisory services and technical advice with respect to legislative and policy requirements for advertising. | Entities submit creatives for review to PSPC. |
| Paragraph 50 | It is impossible that PSPC provided no guidance what so ever to its advisors. PSPC has referred its advisors to the policies and directives which help them conduct their reviews, this in itself is guidance. This language does not reflect the true situation nor the results achieved with the non-partisan review process. In terms of results, prior to the process there were numerous complaints from the public. Since the process has been, there have been no complaints. | We did not find evidence (e.g., manuals or training materials) that the department provided formal guidance to its advisors … |
Public Services and Procurement Canada detailed action plan
| Report reference number | Office of the Auditor General recommendation | Departmental response | Description of final expected outcome/result | Expected final completion date | Key interim milestones (description/dates) | Responsible organization/ point of contact Name, position, telephone number | Indicator of achievement For committee use only |
|---|---|---|---|---|---|---|---|
| Paragraph 4.51 | Public Services and Procurement Canada (PSPC) should provide clear guidance and training to its communications advisors on how to conduct their reviews, including documenting the rationale for their assessments of all non-partisanship criteria. | Agreed. PSPC will create/update training materials and checklists for advisors to ensure that all legislative and policy requirements related to Government of Canada advertising (including non-partisanship, Federal Identity Program, official languages) are applied in a consistent and complete fashion. This is expected to be completed by December 2019. | PSPC has updated guidelines and tools to support the consistent application of legislative and policy requirements related to oversight of non-partisan advertising. | Completed as of October 2019 | Key interim milestone A: Develop a process map of the non-partisan review process to support PSPC advisors in consistent review and documentation of advertising. Date of completion: October 2019. Once developed, the process map was presented to all new and existing advisors to ensure they had a clear understanding of the process and could apply it consistently. Key interim milestone B: Develop checklist to support the non-partisan review process that includes steps connected to the criteria. Date of completion: October 2019. The new advertising management information system, which has been procured and is being configured, will allow for all relevant documentation to be stored in the system itself, including a step uniquely associated with non-partisan reviews. | Jean-Pierre Blais Assistant Deputy Minister Receiver General and Pensions Branch—Assistant Deputy Minister's Office | Not applicable |
Guidance for communications advisors on management of non-partisan review process: June 2019
In this section
Advisory services: Advertising Services Directorate
One of the key requirements of the revised Policy on Communications and Federal Identity requires departments to ensure that communications products are objective, factual and non-partisan. While not an entirely new requirement, a formal, independent review process for advertising was established with Advertising Standards Canada (ASC) to review advertising creative as described in the Terms of Reference: Ad Standards review of non-partisan advertising for the Government of Canada.
The review is mandatory for any campaign with a budget that exceeds $500,000 and is coordinated through the Advertising Services Directorate (ASD) at Public Services and Procurement Canada. The ASC uses established criteria for non-partisan communications, against the following established criteria:
- objective, factual, and explanatory
- free from political party slogans, images, identifiers, bias, designation or affiliation
- the primary colour associated with the governing party is not used in a dominant way, unless an item is commonly depicted in that colour
- advertising is devoid of any name, voice or image of a minister, member of Parliament or senator
It is important to note that all communications products are to meet non-partisan requirements; this includes all advertising regardless of overall campaign value and therefore departments should be striving to meet these requirements similar to federal identity and official languages compliance.
The following will assist advisors to provide a consistent approach to manage the overall process support departments in meeting this mandatory requirement of the Policy on Communications and Federal Identity.
Budget over mandatory limit
- This is the amount established in the Procedures for Mandatory Review. Initial limit established for campaign with total budgets exceeding $500,000
- This limit is currently under review (April 2019) and it is likely that the new threshold will be lower. Additionally, new criteria may be included beyond financial value of campaigns. To be determined
- Campaigns in Advertising Management Information System (AdMIS) with budgets close to this limit should be flagged to the department
- For all campaigns, advisors should enquire and clarify if the campaign is:
- potentially going to continue over multiple fiscal years (impacting budget)
- possibly receive increase in funding during fiscal year
- if yes, then mandatory review should be conducted
Initial submission by department
- Department completes Advertising review submission and evaluation form (accessible to Government of Canada employees only) completely and provides creative materials to advisor via generic mailbox
- Advisor ensures that:
- form is completed fully and accurately
- name of campaign is accurate
- attestation by head of communications is completed
- dates of campaign are indicated accurately
- dates for materials in market input and verified (media plan if available) Note: at the initial review stage, these dates may not be determined; they must still be logical within the stated campaign timeline
- Advisor can also point out any obvious items noted—such as colour or images etc. any claims that may require substantiation, any leading or partisan type messaging etc
- All of this commentary should be saved in either email sent to department, or a note to file that would be saved along with other materials in the shared drive related to the campaign file
- New admission system will allow for this documentation within
- Once complete and accurate, advisor saves department submission and forwards request to Ad Standards for initial review
- Save this in shared drive : …Communications/Advice/Campaigns/year/Department/Campaigns/Name/non partisan
- Initial review completed, share results with department and review any comments or feedback included
- Save documents in the shared drive: …Communications/Advice/Campaigns/year/Department/Campaigns/Name/non partisan
- Take note of any memorable or remarkable advice or questions that you receive so that we can maintain an easy access list of examples to refer to in order to demonstrate the role that is played by ASD
What criteria should advisors look for
While ASD does not conduct actual reviews, our role is to provide advice and guidance on relevant and applicable policy and legislative requirements related to advertising. In fact, all public servants are to follow policy, however there are cases where special attention may be required. As such, advisors can look for the following:
- reference to or promotion of political party specific messages
- presentation of non-approved or pending legislative matters
- broad claims that would require substantiation
- false claims
- obvious spelling errors (we should not be conducting language checks)
- obvious misuse of colour or graphic of the political party forming the government in a dominant manner
- subject matter that relates to Government of Canada priority matters. These issues should be flagged in advance by either Privy Council Office, Treasury Bureau Secretariat (TBS) or other. Examples include, issues mentioned in budget, Speech from the Throne, and mandate letters for ministers, etc.
The new form, implemented in May 2019, provides much more support for the overall process. Advisors however should scan creative to determine if the submissions align with the form information. That is, are the proposed media and or tactics identified matching with the submitted creative materials? If there are any issues or concerns, these should be discussed with the department and documented by email confirming the discussion.
Advisors should routinely document questions, concerns, comments made to departments and save a record of these activities in the appropriate folder on the shared drive within the campaign.
Process for final review
- Departments follow a similar process for final review. The form is completed and adjusted in terms of dates for various creative products. Departments use the information contained in the media plan that is likely completed at this point in time
- Advisors verify the form information to be complete and accurate and that the initial review was completed:
- verify campaign names, budget, overall campaign dates are consistent and the dates of submission are included or updated by advisor
- appropriate attestation from head of communications included
- ensure dates for in market are completed and within scope of overall campaign timelines
- ensure the final form contains the information and signature for the initial review conducted by Ad Standards (AS)
- Form and materials are then submitted by advisor to AS for final review
- Final review is conducted by AS:
- if all is deemed okay, then the information is relayed to department
- final review form sent to TBS
- if there are identified issues these are relayed to the department for clarification and depending on the issue can either be explained or may require adjustment to images or text and then resubmitted
Auditor General of Canada: Spring 2019 reports oversight of government advertising
In this section
Context
On May 7, 2019, the Auditor General tabled spring reports with a chapter that focuses on the oversight of government advertising which has implications for both Public Services and Procurement Canada (PSPC) and the Treasury Board of Canada Secretariat (TBS).
Suggested response
- The government is committed to openness and transparency with respect to advertising
- We welcome the Auditor General's review and accept the recommendation that PSPC should provide clear direction and training to our advisors on how to conduct reviews of government advertising to ensure non-partisanship
- To that end, the department is improving training materials and checklists and this work will be completed by December of this year (2019)
Background
In 2016, for the first time, the Government of Canada defined non-partisan communications, which includes advertising, in the Policy on Communications and Federal Identity. An associated TBS-led review requirement was introduced whereby all advertising campaigns with budgets greater than $500,000 must undergo a mandatory review by an external third party, Advertising Standards Canada. Campaigns with budgets under $500,000 can also be reviewed if departments desire.
The role of PSPC, as defined in the policy, is to facilitate the review process between government departments and Advertising Standards Canada. There is no specific role for PSPC for campaigns with budgets under $500,000. However, because PSPC provides advisory services and technical advice with respect to legislation and policy requirements, including the Federal Identity Program, official languages and non-partisanship, it reviews all advertising materials submitted and, where appropriate, provides advice to departments.
With respect to the recommendation directed at PSPC, the Office of the Auditor General (OAG) reviewed files and documentation related to PSPC reviews and found little evidence that the department reviews campaigns against the non-partisanship criteria. It is for this reason that the OAG recommended that the department undertake training on how to conduct reviews, including documenting the rational for assessments.
Recommendation: Paragraph 53
PSPC should provide clear direction and training to communications advisors on how to conduct their reviews, including documenting the rational for their assessments of all non-partisanship criteria.
Public Services and Procurement Canada response
Agreed.
PSPC will create/update training materials and checklists for advisors to ensure that all legislative and policy requirements related to Government of Canada advertising (including non-partisanship, Federal Identity Program, official languages) are applied in a consistent and complete fashion. This is expected to be completed by December 2019.
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