Description
Advertising or advertizing is a form of communication for marketing and used to encourage, persuade, or manipulate an audience (viewers, readers or listeners; sometimes a specific group) to continue or take some new action.
Government Advertising Policies:
Some Findings from Around the World
Robert Grabow Sankalpa Dashrath Barbara Magid Michelle Moghtader Natasha Noman
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Faculty Advisor: Anya Schiffrin
Acronyms ACPD AdMIS AIR ANC AOR ASA BBC BDUs BPE CanCon CMF COI CPDC CRTC CSA CTF DA DAVP DFP GAGIA GCIS HoC ICC IFNC IMC LPIF MDDA Advertising Co-ordination and Partnership Directorate Advertising Management Information System All India Radio African National Congress (South African ruling political party) Agency of Record Advertising Standards Authority of South Africa British Broadcasting Corporation Broadcast Distribution Undertakings Broadcaster Performance Envelope Canadian content requirements Canada Magazine Fund Central Office of Information Communications Procurement Directorate Canadian Radio-Television and Telecommunications Commission Communication Service Agency Canadian Television Fund Democratic Alliance (South African political party and official opposition to the ANC) Directorate of Advertising and Visual Publicity Directorate of Field Publicity Guidelines for Australian Government Information Activities Government Communication and Information System Head of Communication Independent Communications Committee Independently Funded News Consortia International Marketing Council of South Africa Local Programming Improvement Fund Media Development and Diversity Agency
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MERX MIB MPCC NESB OGC PCO PIB PPP PWGSC RFP RGoB SABC
Canada’s Electronic Tender Service Ministry of Information and Broadcasting Multipurpose Communication Centers Non-English Speaking Background Office of Government Commerce Privy Council Office Press Information Bureau Purchasing Power Parity Public Works and Government Services Canada Request for Proposal Document Royal Government of Bhutan South African Broadcasting Corporation
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Table of Contents
Foreword............................................................................................................................................................................................... 5 Executive Summary ......................................................................................................................................................................... 7 Introduction.......................................................................................................................................................................................10 Public Advertising Case Studies ..............................................................................................................................................14 Public Advertising Case Study 1: Australia ..................................................................................................................15 Public Advertising Case Study 2: Canada ......................................................................................................................29 Public Advertising Case Study 3: India ...........................................................................................................................39 Public Advertising Case Study 4: South Africa ...........................................................................................................52 Public Advertising Case Study 5: United Kingdom...................................................................................................68 Press Subsidies Case Studies ....................................................................................................................................................76 Press Subsidies Case Study 1: Canada ............................................................................................................................76 Press Subsidies Case Study 2: Sweden ...........................................................................................................................82 Press Subsidies Case Study 3: The United Kingdom ...............................................................................................86 A Case for Non-public Advertising Subsidies in Bhutan .............................................................................................91 For More Information...................................................................................................................................................................97 Public Advertising Policies ...................................................................................................................................................97 Misuses of Public Advertising .............................................................................................................................................98 Annual Reports ...........................................................................................................................................................................99 Evaluations of Policy ................................................................................................................................................................99 Tenders ...........................................................................................................................................................................................99 Alternative Media Subsidy Programs........................................................................................................................... 100
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Foreword Professor Anya Schiffrin, School of International and Public Affairs The government of Bhutan is in a historic moment regarding its policies on the media. As the country grows, so will the number of media outlets and their reach. Investment in the media sector will likely expand and also the range of options available to the public. Technology will play an important role in giving readers more choices as to how they get information and what sort of information they choose to receive. Foreign investors will want to step up their involvement in the Bhutanese media scene. Bhutan is in a unique position. Because it is now setting government policy, it can learn from the experiences of other countries around the world and decide which, if any, are compatible with the government’s own goal of promoting Gross National Happiness. Certainly there are pitfalls to be aware of. In many cases, excessive involvement by government has led to media that are beholden and serve as little more than a mouthpiece that does propaganda for government policies. Another category of failures is the use of media by political parties that engage in divisive and distorting reporting aimed at fomenting opposition that undermines meaningful democratic processes. Excessive involvement by corporate owners can lead to capture by special interests and media that promote the political ambitions and financial interests of the owner(s). The rush for profit and circulation can lead to a lowering of standards and coverage that promotes sensationalism and superficiality. None of these scenarios serves the public well. Worse, the prevalence of one often becomes an excuse for the other. For example, governments sometimes use the sensationalism of the media or their factual mistakes as excuses to meddle with editorial independence. There are no easy solutions. Rather, media policies must be viewed as a work in progress, which will likely need adjusting over time. I am honored to present the fine work of my students. The project was born out of a ten-day visit we made to Bhutan last May, which happily coincided with World Press Freedom Day. My offer of research support to the Secretary of the Ministry of Information and Communications was kindly accepted, and I accordingly recruited graduate students at Columbia University with a particular interest in
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media policy and economic development. The team of five has spent many hours collecting data, interviewing policy makers and scholars, and closely examining the experiences of other countries around the world in order to bring to bear information that would be relevant to Bhutan. While we drew on the help of many people in the researching of this report, any factual errors are, of course, our own responsibility. We were privileged to serve the government and people of Bhutan with our work and hope our humble contribution will be of use as you continue your discussion of this important subject. We wish you the very best with your deliberations. Sincerely, Anya Schiffrin Director, International Media, Advocacy and Communications specialization School of International and Public Affairs Columbia University, New York [email protected] Tel: +1 212 854 7188
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Executive Summary
Recognizing the importance of a robust and vibrant media, governments around the world have grappled with the question of how best to support its development. Today, Bhutan is in a similar situation. The policies that are implemented now will set the course for the future and will inevitably have long-term effects that are difficult to predict. It’s impossible to plan for every eventuality, but what can be done is to try to set up a framework that will promote good practices and allow for speedy repair and remediation in the case of difficulties. Part of this framework must be a system of media support that is transparent, has appropriate checks and balances and which promotes arms-length decision making. Respect for the editorial independence of the media should be paramount in all planning.
Using government advertising to subsidize the media is one option that the government of Bhutan is considering, and the Minister of Information of Bhutan has drafted guidelines governing public advertising policy. However, a formal policy has not yet been implemented, and so, in order to augment the Ministry of Information’s extensive research on the subject, the Minister of Information asked a team of graduate students from Columbia University to prepare a report to help inform Bhutan’s on the use of government funds in advertising.
Accordingly, we spent three months researching media advertising policies around the world in order to augment the Ministry of Information research about what has and has not worked in the past. Much of the research and scholarship on this important subject has been done in Australia (previously an example of what not to do), in Canada and in Latin America where the Open Society Justice Initiative has worked to formulate recommendations. Although there is not a vast body of research from which to draw on, there is certainly enough for us to find some “lessons learned” that may be relevant to Bhutan. Our mandate was to look at what sorts of advertising support the Bhutanese government could provide to the local media. However, we found that this question was so closely tied to larger questions of media independence/development that we inevitably strayed into broader policy questions about media support.
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Some of the key findings from our three-month study include:
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There is a wealth of policy options available to governments that wish to promote/develop the media.
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These include direct subsidies, collection of licensing fees, public programming funds, and grants to support local, cultural, “socially beneficial,” and public affairs content.
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Using government advertising to support the media is an extremely risky business, and experts in this area repeatedly warned us against it. They pointed to the potential for corruption and government censorship and cited examples in Argentina, Australia, and South Africa as pitfalls to avoid.
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Using government advertising to support the media is not the same as having the government pay for messaging and campaigning in the media. Examples of this would be government campaigns to promote vaccines for children or tourism campaigns and tenders. This category of advertising is well respected around the world, and countries such as Canada have done an excellent job at laying out frameworks for this kind of arms-length advertising policy. Through these campaigns, Bhutan could promote GNHvalues without the risk of influencing the editorial independence of domestic media.
Below is a summary of some relevant government policies from Australia, Canada, India, South Africa, and the United Kingdom:
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Australia’s current policy was adopted in 2006 in response to nearly a decade of abuse under the Howard administration, during which public advertising was corruptly used to promote a partisan agenda (see Public Advertising Case Study 1). Not surprisingly, the focus of policy recommendations is to depoliticize public advertising, prevent conflicts of interest, and devolve power in such a way that no one person or cabal can easily exploit public advertising for individual or political gain.
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Canada’s well-thought-out government advertising policy, regarded as one of the world’s most transparent, separates small, mundane forms of public advertising known as public announcements (tenders, health advisories, job openings, and office hours) from larger
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initiatives that can include cultural, heritage, and tourism promotion (see Public Advertising Case Study 2). Canada also has strict conflict of interest guidelines, which promote transparency, accountability, and a separation of authority to discourage abuse of public advertising funds for individual financial or political gain. Canada is a useful example for Bhutan in thinking about best practices in public advertising.
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India’s government advertising is based on the premise that in a democracy the government has to ensure that its policies and programs are properly presented and correctly interpreted through the press and other media to the people on whose support and goodwill it holds office1 (Public Advertising Case Study 3).
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South Africa’s transformation into a democratic post-apartheid state in 1994 not only required the unification of a country which had been divided along racial lines for fortysix years (Public Advertising Case Study 4), but also provided an opportunity to improve communication between the government and rural and underserved populations. Awarding government grants to media outlets that promote diversity and facilitate communication with underserved populations has been a success, while South Africa’s attempts to subsidize the press through advertisements failed because of government corruption.
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The United Kingdom has a carefully crafted online tendering system that that helps users search for and understand opportunities (Public Advertising Case Study 5). This system, which documents all open tenders on a central Website, encourages transparency and accountability and provides better “value for money.” The UK also blends thoughtful subsidy programs and funds used to support the media with a demarcated relationship between the government and media in order to preserve public trust.
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Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India. 9
Introduction
Governments around the world pay for advertising in their local media. Some post tender announcements in local newspapers. Others provide health messages, environmental warnings, or safety advisories. Some do employment advertisements, post office hours, or give instructions for obtaining passports. Others promote large campaigns worth hundreds of thousands or millions of dollars. Government advertising can be big business.
Canada’s federal government for example spent 79.5 million Canadian dollars (77.6 million USD) or $2.38 (2.32 USD) for every Canadian in 2009 on public advertising. Of this, $74 million (72.27 million USD) went to large campaigns to educate the public about tax savings accounts, financial reforms in the wake of the contemporaneous economic crisis, and military recruitment initiatives. The balance paid for public announcements, including tender notices representing over $14 billion (13.67 billion USD) in contracts. Most distributions of public funds are made based on merit, but even in Canada’s carefully designed system, abuse is possible. In one instance, “$100 million [97.7 million USD] was paid to a variety of communications agencies in the form of fees and commissions” that were “basically designed to generate commissions for these companies rather than to produce any benefit for Canadians,”2
While the boundary lines can blur, we need to distinguish between advertising that is part of government messaging and daily business and which is common all over the world and advertising that is politically motivated and aimed at handing out subsidies to favored media. This latter form of advertising is now commonly frowned upon in the academic and media development community.
The problem is that, even with the best of intentions, governments giving advertisements intended to support local media often find their policies are corrupted and transformed into subsidies that succor the supporters of those in power. Recent histories of many countries suggest that when public advertising disbursements are conditionally tied to content—even if
2 http://www.cbc.ca/news/background/groupaction/ 10
that content is positively regarded—particularly in environments in which the media are heavily reliant on public advertising for viability, abuse and corruption become common. The lure of personal or political gain is simply too enticing to ignore, and the structures that mandate socially “good” content generally also permit the “bad.” 3
A 2009 report by the Center for International Media Assistance, part of the National Endowment for Democracy, a US government agency based in Washington, DC, notes that Soft, or indirect, censorship can be defined as the practice of influencing news coverage by applying financial pressure on media companies that are deemed critical of a government or its policies and rewarding media outlets and individual journalists who are seen as friendly to the government. Examples of this practice abound in countries in every part of the world.4 Studies in Latin America are often cited as examples of a government policy that has turned bad. In a 2008 report, The Price of Silence, published by the Open Society Institute’s Justice Initiative and the Buenos Aires-based Association for Civil Rights, researchers warned that In most of the [seven] countries studied, we found pervasive abuse by government officials who manipulate distribution of advertising for political and personal purposes—in clear violation of international and regional free expression norms. The effects of such abuses are especially insidious when public sector advertising is critical to the financial survival of media outlets, which is particularly true for local media.5
As examples from around the world suggest, connecting media support to government policies often undermine media independence. We hope that our case studies from around the world provide some useful background information The question of how to subsidize the media in Bhutan is certainly a crucial part of any government media policy.
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf. http://cima.ned.org/publications/research-reports/soft-censorship-how-governments-around-globe-use-moneymanipulate-medi 5 The report, which includes guidelines for advertising policy can be found here: http://www.soros.org/initiatives/justice/focus/foi/articles_publications/publications/silence_20080811
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Public Advertising Case Studies
The old adage holds that we study history to learn from past mistakes and to avoid replicating them in the future. Today, as Bhutan develops its policy, the country is perfectly placed to acquire information from the public advertising histories of other countries. As Bhutan creates its government advertising policy, it may be helpful to learn from mistakes of other actors in this arena or to examine some best practices from across the globe. The team chose five countries to examine in greater depth: Australia, Canada, India, South Africa, and the United Kingdom. These countries were all chosen for closer analysis because they may be able to aid Bhutan in developing its guidelines—either towards certain practices that have proven successful or away from what have emerged as policy failures. Although the lessons from these five countries must be condignly contextualized, the information below may prove useful for Bhutan.
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Public Advertising Case Study 1: Australia
Executive Summary Australia’s government advertising policy was implemented in 2006 in response to nearly a decade of abuse under the Howard administration during which public advertising was used to promote a partisan agenda.
Australia: From Abuse to Reform In Australia between 1996 and 2005, the Howard government spent more than AU$1 billion (971.5 million USD) on advertising that was widely considered to be partisan.6 There are clear, documented cases of spikes in government advertising spending prior to elections.7 In 2004 alone, just months before the election, Howard’s government spent upwards of AU$30 million (29.2 million USD) on advertising the accomplishments of the government.8 Howard’s advertising was no secret; many in the opposition and in the general public understandably viewed these timely advertising campaigns as a strategy to garner support for the incumbency in the lead-up to the elections. Calls for change and increased regulations came from auditor general reports, Parliamentary inquiries, and Private Members’ Bills.9 But change was slow in coming. Although against the spirit of public advertising, the government’s actions were not considered strictly illegal according to the guidelines regulating government advertising at the time.10 During the government’s decade-long abuse of advertising, the guidelines at the time—the Guidelines for Australian Government Information Activities (GAGIA)—were neither robust enough nor specific enough to prevent the misuse of funds. In fact, the GAGIA contained no clauses protecting advertising from being used to promote a government’s political agenda.11 The authors of the GAGIA addressed how a government should spend money but did not have
6 Sally Young, “Reform and Resistance: The Regulation of Government Advertising in Australia,” (refereed paper presented to the Australian Political Studies Association Conference, University of Newcastle, September 25-27). 7 Sally Young, “Not Biting the Hand that Feeds: Theories for understanding government advertising in Australia,” Democratic Audit of Australia—August 2005, 2. 8 Sally Young, “Political advertising: hey big spender!” in Mortgage Nation:The 2004 federal election, ed. M. Simms and J. Warhurst (Perth: API Network). 9 Young, “Reform and Resistance.” 10 Young, “Theories for understanding government advertising in Australia,” 2. 11 Young, “Theories for understanding government advertising in Australia,” 2.
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the foresight to adequately address how the government should not spend money. In the absence of strict regulations to curb abuse, institutional mechanisms were also lacking.
However, change did come, and in July 2008, the Rudd government released the “Guidelines.” These guidelines were strict on what a government would not be permitted to use advertising funds for. On July 2, 2008, Lindsay Tanner MP and Senator John Faulkner wrote a press release that explained that: “these new procedures [the Guidelines] will now give the public confidence that campaigns are legitimately authorised, properly targeted and non-political . . . This [new] guideline ensures that a Government cannot advertise, as ‘government policy’, a proposed election policy, as the Howard Government did in its tax advertising campaign in 1998.”12
To prevent further abuses and ensure appropriate policies, Allan Hawke was appointed to conduct an independent review of the Guidelines, which was released publicly in March 2010.13 Shortly thereafter, the amended and most recent version of the Guidelines was released.
Years of Abuse: Why Was the Status Quo Maintained? To understand why the government’s guidelines were inadequate during Howard’s reign, it is important to understand a little about the history of government advertising in Australia. Before the 1990s, there was no reason for skepticism regarding government advertising. In the 1970s, the government began using advertising campaigns, which usually received bipartisan support, to inform the public of basic health messages and social wellbeing.14 In the 1970s, a gentlemen’s agreement dictated the rules of the game: taxpayer money would not be used to advance a particular party’s political agenda.15 Because of this governmental self-restraint, protections against the use of government advertising money for partisan purposes were not adequately codified in government advertising laws.
It was only in the late 1980s and the 1990s that the Australian governments began to stray from
John Faulkner and Lindsay Tanner, “Joint Media Release: New Advertising Guidelines,” Minister for Finance and Deregulation, July 2, 2008. 13 “Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009–10,” Financial Management Group, Australian Government Department of Finance and Deregulation, Financial Management Group, October 2010. 14 Young, “Reform and Resistance.” 15 Young, “Reform and Resistance.” 16
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these unwritten agreements, and for the first time public monies were used to advance a partisan goal.16 But the guidelines were not amended until 2008, a couple of decades after the emergence of this abusive behavior. How is it possible that Australian advertising guidelines were not amended until 2008? Why did clauses ensuring that public funds would not be used for political advertising not appear beforehand?
The political, economic, and media climate of Australia is generally considered to be “advanced” or “developed.” Yet despite continued and conspicuous use of government advertising to push a partisan agenda, reform moved very slowly. The answer, not surprisingly, lies in politics and economics. Conflicts of interest among many actors slowed change. Because a number of powerful or influential entities benefited from the previous advertising arrangement, disincentives for change were strong. Both the incumbency, which benefited politically, and the media, which benefited economically, had few reasons to reform the system.
Politically, change stalled for many reasons. While Howard’s opposition was vocal in its criticism of the government’s use of advertising for its own agenda, the incumbency benefited from the status quo. Sally Young, a leading Australian scholar on government advertising policy, refers to the political climate of Australia at the time as “cold,” meaning that “government, obtaining a ruling party benefit from an existing system, has demonstrated long-term resistance to any reforms despite attempts by other, usually influential, policy actors to achieve change.”17 Politically, in this “cold” climate, change stalled because the incumbency resisted policy modifications.
But why did the media, traditional whistleblowers, not play this particular role and alert the public to these corrupt practices? Economics. In this advertising climate, government funded the very sources that could have exposed this form of injustice. Media sources that received government advertising revenue were less likely to report on the government’s advertising abuses, however partisan, for justifiable fear that the government would pull its ads.
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Young, “Reform and Resistance.” Young, “Reform and Resistance.” 17
Sally Young goes through a comprehensive analysis of media and supports this rational economic theory with data: While commercial television news has only infrequently reported the issue of government advertising (Young 2006b), newspapers (which profit far less from government advertising) have regularly called for change. For example, newspapers have used bluntly worded editorials to express their concerns over the federal government’s advertising with headlines such as: - ‘The costs of self-promotion’, the Sydney Morning Herald, 29 June 2004. - ‘Playing politics advertorially’, the Canberra Times, 1 July 2004. - ‘Government advertising over the top’, the Courier Mail, 1 July 2004 - An advertising rort’, the Australian, 31 August 2005.18 As Sally Young herself points out, this logic falls perfectly into Herman and Chomsky’s framework of propaganda theory.19,20 Because the government is unlikely to place advertisements in press critical of its policies, economic logic stipulates that those who remain quiet will be those who continue to receive government subsidies in the form of paid advertisements. “TV and radio stations are particularly vulnerable to this filter because broadcasters obtain about 100 per cent of their revenue from advertising (while newspapers derive less, about 75 per cent).”21 Not surprisingly, Howard’s government employed television advertising most heavily.22
The Good News (and Some Warnings) Although it is too early to say definitively, Australia seems to be a success story. From a history of abuse and partisan government advertising, have emerged robust, new guidelines, institutions to enforce them, and a stronger system of checks and balances.
Australia’s example poses questions for Bhutan. How can the country prevent an “Australia”? How can it ensure that there are laws and enforcement systems that are able to prevent use of
Young, “Reform and Resistance.” Edward S. Herman and Noam Chomsky, “A propaganda model” in Manufacturing Consent (Pantheon Books, 1988). 20 Young, “Theories for understanding government advertising in Australia,” 7. 21 Young, “Theories for understanding government advertising in Australia,” 7. 22 Young, “Political advertising.”
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government funds for a partisan political agenda? How can it make sure that the government is not subsidizing media for reasons of political self-interest rather than ideals of GNH or the greater good? Bhutan must create a policy that is robust enough to prevent partisan abuse but flexible enough to accommodate changing contexts and the emergence of new technologies.
Australia’s System: The Good, the Bad, and Implications for Bhutan The following section analyzes the specifics of Australia’s government advertising policy, with a close look at the pros and cons of the specific guidelines where appropriate. These findings are applicable to many countries, although a country’s context will determine the exact adaptation. All of these, after adaptation to the local context, can inform Bhutan’s advertising policy.
Advertising Rationale Australian government campaign advertising expenditures for the financial year 2009–2010 were reported at 114.7 million Australian dollars.23 Such a large budget line must be closely
monitored and have a well-thought-out rationale.
In the case of Australia, advertising serves two general purposes: “at one level, government advertising has an important democratic function. The public has a right to be informed about the programs that their taxes fund. Equally, governments have a right to establish a framework for delivering this information, subject to parliamentary scrutiny.”24
The guidelines explain that: 8. The underlying principles governing the use of public funds for all government information and advertising campaigns are that: a. members of the public have equal rights to access comprehensive information about government policies, programs and services which affect their entitlements, rights and obligations; b. governments may legitimately use public funds to explain government
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“Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009–10.” “Research Note: Information, Analysis and Advice for the Parliament,” Parliamentary Library Department of Parliamentary Services, June 21, 2004, No. 62. 19
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;25 Democratic governments must justify their spending to the public and must also be able to communicate information to promote wellbeing through information campaigns.
Types of Advertisements The types of advertisements used by the government are in keeping with the two general purposes of the government’s advertising rationale. Public monies and taxpayer dollars go towards non-campaign advertising in Australia, which includes, but is not limited to:
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recruitment for specific job vacancies; auction and tender notices; invitations to make submissions or apply for grants; notification of date- and/or location-specific information (for example, notification of a public meeting at a particular time and place); and other public notices.26
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The Big Five There are five principles by which all government advertising campaigns must abide. Collectively, they clarify the purpose of the campaigns, requiring relevance, coherence with the end goal, objectivity, efficiency, and legality:
Principle 1: Campaigns should be relevant to government responsibilities. Principle 2: Campaign materials should be presented in an objective, Fair, and accessible manner and be designed to meet the objectives of the campaign. Principle 3: Campaign materials should be objective and not directed at promoting party political interests. Principle 4: Campaigns should be justified and undertaken in an efficient, effective,
“Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies,” Commonwealth of Australia, Department of Finance and Deregulation, March 2010. 26 “Guidelines on Information and Advertising Campaigns.” 20
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and relevant manner. Principle 5: Campaigns must comply with legal requirements and procurement policies and procedures.27
Principle 3 is crucial, given Australia’s history; above all, Australia’s government advertising guidelines were amended so that they would not be used for partisan agendas or for the promotion of a particular policy, as has happened in the past.
Clear Definitions Australia’s Guidelines include clear definitions throughout, leaving no room for ambiguity. A campaign, for example, is defined as the following: “For the purposes of these Guidelines, an advertising campaign involves paid media placement and is designed to inform, educate, motivate or change behaviour.”28 Clearly outlined definitions promote clarity. However, governments must be wary of making the definitions too narrow to apply to evolving contexts.
Localized Advertising In Australia, there are provisions for local advertising and “both Commonwealth and State governments are entitled to taxpayer money to provide the public with information about their programs.”29 This decentralized campaign allows for local governments and authorities to address the local, state-specific needs of the population through more targeted, relevant, or appropriate campaigns. Because the governments of different states have different issues to communicate to the public, targeting a specific audience may also be more cost-effective. However, it also leaves room for great diversity of messaging from government bodies, and potential disparities in information coverage. Australia is a very large, developed country with high quality infrastructure. It is important to take geography and infrastructure into consideration when planning how localized advertising should be addressed.
Targeting Disadvantaged Groups According to Australia’s guidelines, “special attention should be paid to communicating with
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“Guidelines on Information and Advertising Campaigns,” 10. “Guidelines on Information and Advertising Campaigns,” 9. 29 “Research Note.” 21
any disadvantaged individuals or groups identified as being within the target audience. Particular attention should be paid to the communication needs of young people, the rural community and those for whom English is not a convenient language in which to receive information.”30 Likewise, “imagery used in campaign materials should reflect the diverse range of Australians. There should be recognition of the full participation of women, Indigenous and culturally and linguistically diverse communities by realistically portraying their interests, lifestyles and contributions to Australian society.”31
Although Australia is predominantly English-speaking, Australia makes an effort to reach those who are linguistic minorities. For example, in the government’s advertising budget, “specialist consultants and translation costs” appear under two budget lines: Non-English Speaking Background (NESB) Communications and Indigenous Communications.32 In countries with linguistic diversity, language-specific local advertising provisions will ensure that messaging is delivered in a manner that is comprehensible and familiar to as many people as possible. Theoretically, one could argue that advertising in multiple languages would detract from cultural unity, however getting important messages out to linguistic minorities, particularly concerning public health and safety, will benefit society at large.
Advertising Platforms The government of Australia disseminates advertising through “print, radio, digital, cinema, television or out-of-home media.”33 Different types of media allow the government’s advertising broad reach—people from different socioeconomic and cultural backgrounds may access information preferentially through only one medium. Broadening advertising channels can allow diversification of recipients. In the case of countries with illiterate populations or with infrastructural challenges, newspaper and digital advertising may not be appropriate, for example. Depending upon the income level and electric grid of a country, TV or radio may be an appropriate means through which to advertise. Cell phones, which have recently become
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“Guidelines on Information and Advertising Campaigns.” “Guidelines on Information and Advertising Campaigns.” 32 “Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009-10,” 15. 33 “Guidelines on Information and Advertising Campaigns,” 11. 22
available to many at low cost, even those on the so-called bottom of the pyramid, are another means of reaching disadvantaged, remote, or impoverished populations.
Cost should also be considered in choosing an advertising medium. Since governments, particularly poorer governments, are operating in conditions of limited resources, it is important that advertising and messaging be as economically efficient and cost-effective as possible. For example, in Australia, “the cost of government advertising is minimized by the targeted use of media other than television advertising.”34 In fact, the guidelines stipulate that “the medium and volume of the advertising activities should be cost effective and justifiable within the budget allocated to the campaign.”35 In Australia and much of the developed world, digital advertising has minimized costs while maximizing reach. However, this may be neither practical nor effective in other countries with differing digital landscapes. The independent review recognized the tension between reach and cost-effectiveness in some cases, stating that “in practice, there can be a conflict between the objective to achieve savings and the Government’s duty of care to ensure all members of the public have equal access to comprehensive information.”36 It is important to target all members of society, not simply the ones who are conveniently and cheaply accessible.
It is also crucial to have a system of monitoring and evaluation in place. It is important to evaluate the outcomes/impact of advertising schemes, to ensure broad coverage, cost-efficiency, and effectiveness. The guidelines stipulate that: “campaign materials should be tested with target audiences to indicate they are engaging and perform well against the objectives of the campaign.”37 Pre-testing is also recommended so that necessary changes can be made to a campaign before it goes public.
Accountability Government advertising guidelines alone will not prevent taxpayer money from funding partisan advertising. An adequate, uncorrupted enforcement system is also necessary.
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Allan Hawke, “Independent Review of Government Advertising Arrangements,” February 26, 2010. “Guidelines on Information and Advertising Campaigns.” 36 Hawke, “Independent Review of Government Advertising Arrangements,” 20. 37 “Guidelines on Information and Advertising Campaigns,” 10. 23
The framework for government advertising campaign scrutiny has changed over the course of the past few years. The most recent iteration dates from March 2010. New accountability and reporting procedures were put into place, and the Independent Communications Committee (ICC) was established: The ICC provides a report to agency Chief Executives on whether campaigns comply with Principles 1 to 4 of the Guidelines. It is ultimately the responsibility of the Chief Executive to consider whether a campaign fully complies with the Guidelines (including compliance with legal requirements and procurement policies) and to ask the relevant Minister to launch the campaign or approve its launch. The ICC’s advice to Chief Executives is published on the Finance website as soon as possible after the launch of relevant campaigns. Chief Executives must also publish their certification of compliance with the Guidelines on their agency website when the campaign launches.38 It is hoped that this system will now be robust enough to prevent further abuse. The new policy incorporates checks and balances to make sure that no party has a conflict of interest that could lead to misuse of government advertising. It is important to separate the campaign designers and conceivers from the approvers and funders.
While this is important, it may also be helpful to have a centralized agency to coordinate government advertising. The Independent Review explains that:
“coordination by a central agency is necessary and appropriate to: (a) ensure whole-of-government perspectives are brought to bear; (b) avoid duplication, competition in the advertising market and conflicting messages; (c) compensate for varying levels of capability in departments; (d) raise issues at an early stage; and (e) coordinate contract management and procurement.”39
Financial reporting and accountability are crucial; in an attempt to promote accountability and
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“Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009-10,” 9. Hawke, “Independent Review of Government Advertising Arrangements,” 21. 24
transparency, a full report and detailed budget must be produced for Parliament biannually.40 Australia’s past shows the need for accountability and transparency to ensure that a particular partisan agenda is not unjustly promoted. For this reason and following just that, the system of checks and balances in Australia was restructured in 2008 and further tweaked in 2010. Checks and balances are crucial in all governments, although that accountability must not come at the cost of all else. A system with too many checks and balances may become clumsy, bureaucratic, and slow, something to keep in mind when creating a policy and enforcement mechanisms.
Campaign Threshold For this reason, a campaign threshold was implemented; campaigns over AU$250,000 (242,875 USD) are scrutinized by the auditor general: “the Independent Communications Committee considers campaigns and provides advice to Chief Executives on all advertising campaigns valued at more than AU$250,000 (242,875 USD) or where requested to do so by the Chief Executive.”41 Although this figure would need to be amended for different countries, it serves to cut down considerably on bureaucracy and push smaller, cheaper campaigns more quickly through bureaucratic roadblocks. It is possible that this efficiency comes at a price: it is much harder to prevent against corruption or misappropriation of funds, however small the scale, with this type of threshold.
Bureaucracy In the Independent Review of Government Advertising Arrangements, Hawke stressed the need for: “communications flexibility, to adopt new technologies, and to adjust elements of a campaign while it is underway. It would be desirable for the Guidelines and associated arrangements to be more adaptable to emerging trends.”42 Because of past abuses, the government advertising policy was understandably wary of allowing for changes in midcampaign advertising, as these are difficult to monitor. Although restrictions on mid-campaign changes can be an important piece of accountability assurance, it may also hinder a campaign’s efficacy. Perhaps the pendulum has swung too far in the other direction.
40 41
“Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009-10,” 9. “Guidelines on Information and Advertising Campaigns,” 6. 42 Hawke, “Independent Review of Government Advertising Arrangements,” 21. 25
In fact, the agencies touched on a number of these shortcomings in the 2008 Guidelines in their feedback. Specifically, Feedback from agencies indicates that the current approval processes: (a) result in delays in delivering advertising campaigns by required timeframes; (b) impose significant cost burdens on agencies; (c) involve a very high administrative burden, particularly in fulfilling the AuditorGeneral’s requirements; (d) have resulted in missed advertising opportunities and a limited ability to adopt new media technologies; and (e) re-certifications of variations to campaigns do not allow campaigns to be adjusted after commencement to reflect feedback or changed circumstances, and have hampered agencies’ abilities to respond to cost-effective media opportunities that arise at short notice.43 Exceptional Circumstances Australia’s policy is subject to suspension in the case of extreme necessity, though it must formally report to the Parliament: “the Cabinet Secretary can exempt a campaign from compliance with these Guidelines on the basis of a national emergency, extreme urgency or other compelling reason. Where an exemption is approved, the Independent Communications Committee will be informed of the exemption, and the decision will be formally recorded and reported to the Parliament.”44 This clause is both crucial and worrisome. It is important that governments be able to communicate with the public during an emergency without going through cumbersome advertising approval procedures. However, allowing suspension comes with risks. To prevent abuse, there must be political mechanisms that place checks on when an emergency can be called, and by whom. It is crucial that strong institutions prevent a political actor from declaring a state of emergency as a simple abuse of power. Although this goes beyond the purview of the advertising guidelines, strong political mechanisms and strong institutions form the foundation of a strong government advertising policy. Government advertising does not
43 44
Hawke, “Independent Review of Government Advertising Arrangements.” “Guidelines on Information and Advertising Campaigns,” 5. 26
exist in a vacuum. It is both affected by and supportive of a larger political system.
Feedback and Independent Review As previously mentioned, Australia’s government sponsored an independent review of government advertising policy, and then requested internal departmental feedback. This process allowed a disinterested, external reviewer to evaluate Australia’s policy and provide unbiased feedback. Allowing for departmental input also ensured that those on the inside, with intimate knowledge of the policy’s practice and implementation, had more ownership of the process. If non-repressive, free institutions are in place and external evaluators have nothing to fear from providing honest criticism, this process of periodic, independent review can be beneficial in keeping the system modern, accountable, and efficient. But if an independent evaluator is not free to provide criticism, this review will become an exercise in diplomacy or inutility. The risk of constant review, feedback, and change, of course, is that a system would become too reactionary or tighten too much. Government policies should not be regularly rewritten but should be supple enough to adapt to changing contexts.
Comparison between Australia and Bhutan There are clear historical, demographic, and geographic differences between Australia and Bhutan, and analyzing Australia’s government advertising policy in order to inform Bhutan’s may not seem like a natural choice at first glance. One could put forth a handful of arguments highlighting the similarities between the Commonwealth and Bhutan. Both countries try to strike a balance between environmental protection and economic development, for example. Both are working towards a “holistic” model of development. But frankly, at least as much distinguishes them as unites them.
Australia is a developed regional superpower—Bhutan a small, relatively isolated developing country. Australia, rich in natural resources, is endowed with a 25,760 km coastline.45 Bhutan, on the other hand, is a small, landlocked country. The CIA’s World Factbook estimated Australia’s population of 21,262,641 to be ethnically homogeneous, with 92 percent whites, 7 percent
“The World Factbook: Australia,” CIA, accessed October 20, 2010, https://www.cia.gov/library/publications/theworld-factbook/geos/as.html. 27
45
Asians, and 1 percent Aboriginals and others.46 On the other hand, with a population of just under 700,000, Bhutan’s ethnic groups are more evenly weighted with Bhote comprising 50 percent of the population, Nepalese 35 percent, and indigenous or migrant tribes 15 percent.47 Literacy is high in Australia, and 99 percent of the population, both males and females, is estimated to be literate. In Bhutan, 47 percent of the population but only 34 percent of females was estimated to be literate as of 2003.48 Linguistically, the countries are distinct as well—a reflection of the ethnic make-up of the populations. According to Mr. Joseph Lo Bianco, Chief Executive of the National Languages and Literacy Institute of Australia, “English has no de jure status but it is so entrenched as the common language that it is de facto the official language as well as the national language.”49 Bhutan has much more linguistic diversity: Dzongkha is the official language, but various Tibetan and Nepalese dialects are also widely spoken.
The countries’ economic landscapes are also very different. Australia boasts a competitive and thriving market economy. Gross Domestic Product (GDP), adjusted for Purchasing Power Parity (PPP) was estimated to be 851.1 billion USD in 2009, or 18th in the world.50 GDP per capita was estimated at $40,000 USD or 19th in the world.51 In stark contrast, Bhutan ranks 170th for global GDP (PPP adjusted), and in 2009 GDP per capita was estimated to be $4,700 USD.52 It is important to note the limitations of GDP as an indicator, however. GDP has been widely criticized as Western-biased and inadequate when it comes to measuring “what matters.” Bhutan has led the world in the development of its own holistic system of evaluating “progress” or “development”—Gross National Happiness. GNH seeks to go beyond GDP in defining wellbeing through the four pillars of sustainable development, cultural values, natural environment, and good governance. GNH, the abovementioned factors, and many others, must
“The World Factbook: Australia.” “The World Factbook: Bhutan,” CIA, accessed October 20, 2010, https://www.cia.gov/library/publications/theworld-factbook/geos/bt.html. 48 “The World Factbook: Bhutan. 49 Joseph Lo “Pluralist Nations: Pluralist Language Policies?” (at the 1995 Global Cultural Diversity Conference Proceedings, Sydney). 50 “The World Factbook: Australia.” 51 “The World Factbook: Australia.” 52 “The World Factbook: Bhutan.”
47
46
28
be considered when applying Australia’s lessons to the Bhutanese context. Although more than geography separates Australia and Bhutan, lessons from Australia’s experience can be applied to any country developing or reforming its government advertising policy, including Bhutan. Australia was selected for analysis not because of its similarity to Bhutan but because the history of Australia’s government advertising policy serves as a warning to all countries regardless of geography, politics, or culture. Australia’s current policy is shaped by experience, and the lessons learned are universally applicable and widely scalable. Following downright abuse by the Australian government, which used public advertising to forward its own interests, Australia reformed its policy. While a historical analysis of Australia’s government advertising policy is useful in informing governments what not to do, the country’s robust guidelines today paint a picture of massive policy shifts and positive reform and can provide insight into what to do. To be viable, the recommendations contained within this paper must be tailored to the Bhutanese context. But the main lesson from Australia’s experience—the importance of protecting government advertising from being used to further partisan political agendas—is of universal importance. By Barbara Magid [email protected]
Public Advertising Case Study 2: Canada
Executive Summary Canada’s well-thought-out advertising policy separates small, mundane forms of public advertising, known as public announcements (tenders, health advisories, job openings, and office hours), from larger initiatives that can include cultural, heritage, and tourism promotion. The country also has strict conflict-of-interest guidelines, which promote transparency,
accountability, and a separation of authority to discourage abuse of public advertising funds for individual financial or political gain, which may be of interest to Bhutan.
Purpose of Government Advertising in Canada
29
The stated purpose of government advertising in Canada is to “ensure that communications across the Government of Canada are well co-ordinated, effectively managed and responsive to the diverse information needs of the public.”53 More specifically, government advertising aims to inform the public in an open, fair, and cost-effective way about government policies, programs, and services (and how to benefit from them), allowing the government to communicate with citizens and citizens to communicate and give feedback to the government. For example, public advertising provides people instructions on “where to click, call or visit, so that the public can take action on matters that are important to them in an easy, convenient, and timely manner.”54
The Decision to Advertise In Canada the decision to advertise begins with the individual institution—usually the communication head of the department—which may do so and purchase advertising space or time in any medium to inform Canadians “about their rights or responsibilities about government policies, programs, services, or initiatives,” or about tenders or “risks to public health, safety, or the environment.”
Types of Advertising Canada cleaves advertising into two camps: promotion of government priorities, also known as initiatives, and public notices, commonly referred to as public announcements. Approximately $74 million (72.3 million USD)of Canada’s $79.5 million (77.6 million USD) 2008 federal public advertising budget was used to promote government priorities, predominately in large campaigns.
Large Campaigns Among the many examples were the following: The Consumer Product Safety Campaign to increase awareness among Canadians about potential hazards associated with products purchased outside Canada, Celebrate Canada’s Culture Initiative to recruit professional artists to represent Team Canada in an international cultural competitions in Lebanon, and Advantage Canada, to
53 54
http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 30
drum up awareness about the government’s economic action plan to reawaken the depressed economy.
Public Notices Canada used the remaining $5 million (4.8 million USD) in its budget for public notices, such as tenders (which, subject to competitive bidding, awarded $14 billion—13.67 billion USD—in contracts in 2006), health advisories, and public meetings or hearings, as well as more mundane advisories like government business hours, federal employment opportunities, and information about how to get a passport.
Language of Advertising Canadian law mandates that all public advertising be available in English and French, further stipulating that government institutions ensure that “positive measures” are taken to implement Canada’s commitment to “enhance the vitality of official language minority communities and address the needs, concerns and languages preferences of such communities.”55
Political Neutrality of Public Advertising Public advertising is legally bound to be apolitical: “Institutions must not use public funds to purchase advertising in support of a political party.”56 Even with good laws in place, of course, the means of misusing political funds, particularly during campaign season exists. In a hypothetical scenario, for example by offering information about great work done by the current government, the ruling party could imply that it deserves credit for the advertised successes. To mitigate the risk of this and other types of political-focused abuses, all government institutions must “suspend their advertising during general elections,” except when “an institution is required by statute or regulation to issue a public notice for legal purposes,” which includes health advisories, safety or environmental concerns, or employment or staffing notices.57
Learning from the Past: Separating Authority
55 56
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 57 http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 31
Following a 2004 scandal in which Canada’s federal auditor found that “$100 million [97.7 million USD] was paid to a variety of communications agencies in the form of fees and commissions” that were “basically designed to generate commissions for these companies rather than to produce any benefit for Canadians,”58 the government amended its already careful policy and structure to provide great accountability and transparency and arguably needed bureaucracy through a more rigorous separation of entity responsibilities, divided as those (1) requesting funds, (2) approving funds, (3) releasing funds, (4) overseeing funds, (5) producing ad campaigns and buying ad space, and (6) measuring the effectiveness of the campaign.
Structuring an Advertising Policy The process works thus. Once a public institution decides to advertise, there are five key actors involved: (1) the institution requesting funding; (2) Public Works and Government Services Canada (PWGSC), which has three important, relevant organizations, (a) the Agency of Record, (b) the Advertising Co-ordination and Partnership Directorate (ACPD), and (c) the Communications Procurement Directorate (CPD); (3) the Privy Council Office (PCO); (4) the Treasury; and (5) the Cabinet. Six basic stages are involved in the development and execution of an advertising initiative: (1) planning and approval, (2) contracting for advertising services, (3) advertising production, (4) pretesting (only for large campaigns), (5) media placement, and (6) a post campaign evaluation and report.59
1. Planning and Approval. A public institution looking to advertise works with the Privy Council Office (PCO) to develop an advertising proposal that includes objectives, target audiences, measurable outcomes, and strategy. Once complete, PWGSC reviews the proposal for legal compliance before passing it on to the Cabinet, which approves proposals (under the umbrella Government Advertising Plan), twice annually. Following Cabinet approval, institutions submit the proposal to the Treasury for funding.60
2. Contracting for Advertising Services. Once funding is approved, institutions contact the ACPD and CPD within the PWGSC to initiate the contract and implementation process, submit a
58 59
http://www.cbc.ca/news/background/groupaction/ http://www.tbs-sct.gc.ca/pubs_pol/sipubs/comm/cpgcp-ppcgc03-eng.asp#_Toc137523379 60 http://www.tbs-sct.gc.ca/pubs_pol/sipubs/comm/cpgcp-ppcgc03-eng.asp#_Toc137523379 32
“scope of work,” and then receive a project registration number from the ACPD. The CPD, with input from the ACPD and the institutions to find suppliers, issues an advertising contract, and then the CPD is charged with managing the contract and ensuring proper administration and documentation.61
3. Advertising Production. Institutions work with their selected contractors to develop the advertising strategy, design, and create final advertising materials for print, broadcast, or electronic media. Along the way, institutions must advise the ACPD and CPD of any changes in the original scope of work or media buy strategy.62
4. Pretesting. This applies only to large campaigns exceeding $400,000 (390,625 USD) in media buy, which then require benchmarking and focus grouping.63
5. Media Placement. Institutions develop a media-buy plan with their advertising services contractors, review and approve them internally, then submit them to their PCO strategic analysis for review. Once reviewed, the institution submits the plan to ACPD for a buy authorization. Once authorized, the Agency of Record—a private contracting entity within the PWGSC selected through a competitive bidding process—purchases the media space. The Agency of Record, however, cannot purchase media for an institution unless a work authorization and project work number have been assigned.64
6. Post Campaign Evaluation and Report. This applies only to large campaigns exceeding $100,000 (97,656 USD) in media buy. In addition to monitoring Website hits and page views after a campaign, the Canadian Government monitors calls to 1-800-CANADA, the country’s toll-free hotline for information about any important government initiatives or public announcements, where citizens can also voice concerns and complaints and have them
61 62
Ibid Ibid 63 Ibid 64 http://www.tbs-sct.gc.ca/pubs_pol/sipubs/comm/cpgcp-ppcgc03-eng.asp#_Toc137523379 33
addressed. All calls are coded and associated with the appropriate public advertising initiative and campaign.65
This model, while admittedly bureaucratic, helps ensure sufficient oversight and separation of authority to hedge the risk of potential abuses. The sophistication and accountability of the model also provide political cover for persons interested in increasing the public advertising budget, even in this case, in the wake of a recent public advertising scandal. Four years after the shakedown, the Harper administration “more than doubled the government’s ad budget, increasing it from $41.3 million (40.3 million USD) to $86.9 million (84.9 million USD).”66 And despite questions in the Montreal Gazette, such as, “Did this increase involve advertising with a partisan sub-text? Were there legitimate reasons for the spend to spiral?” the plan moved forward. 67
Selecting an Advertising Platform The Government of Canada thus advertises in all forms of media. With each campaign, in deciding which platform to use, the institution looking to advertise (or its supervising agency) considers the weight of the objectives, audience demographics, research about the target audience, media availability, reach, costs, and two-language and minority-language considerations. Excluding public notice buys, which institutions can purchase directly without approval from the Agency of Record, the table below, which shows a modest decrease in aggregate and per capita spending on public advertising, breaks down government advertising amounts by platform in 2008–2009 and provides totals for 2006–2009. Since 2006, government advertising has marginally and steadily decreased in aggregate and per capita figures.68
Fig 1: The 2008–2009 platform breakdown of aggregate and per capita government advertising in millions of $, except per capita figures which are in standard $.69 Platform Type Expenditure (’08–’09) Expenditure (’08–’09) % of Total (’08–
65 66
http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf http://www.suite101.com/content/government-advertising-policies-a63439 67 http://www.suite101.com/content/government-advertising-policies-a63439 68 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 69 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 34
Millions of Canadian Millions of US Dollars Dollars Weekly/Community $6.15 Papers TV $20.71 Radio Magazines Cinemas Out of Home Internet National Dailies Total ’08–’09 Total ’07–’08 Total ’06–’07 $8.67 $1.67 $1.54 $6.49 $8.91 $11.79 6 USD 20.22 USD 8.47 USD 1.63 USD 1.50 USD 6.34 USD 8.70 USD 11.51 USD
’09)
9.33 31.41 13.15 2.53 2.34 9.84 13.52 17.88
$79.5 ($2.38 per capita) 77.6 USD (2.32 per capita) $84.1 ($2.55 per capita) 82.1 USD (2.49 per capita) $86.9 ($2.66 per capita) 84.9 USD (2.60 per capita)
Targeting Audiences Outside of Canada While institutions may place or purchase advertising directed at audiences outside of Canada to promote Canadian interests, before doing so they must consult with Foreign Affairs and International Trade Canada to ensure compatibility with government communications and marketing abroad.70
Domestic-owned Media Considerations There are no provisions that mandate that public funds can be used only to buy space in Canadian-owned media—that is governed by law. However, recent laws changed the requirement that the firms providing advertising services be 100 percent Canadian-owned to at least 80 percent Canadian-owned.71
Withdrawing Public Advertising Beyond the ability to cancel media purchases two months prior to national elections, or in the event of violation of the government’s public advertising guidelines, specific circumstances
70 71
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 35
under which the government may withdraw advertising are elusive. It appears that the Agency of Record, which is closely monitored by the PWGSC, has the ability to withdraw funding in accordance with law and public advertising guidelines. While the ACPD may withhold issuance of or cancel a project registration number, which would effectively end a campaign, the central consideration—and where the bulk of the risk resides—seems to be in the selection of the company used to produce the advertising and separately the media buys, both of which are selected through competitive bids.72
Efficiency in Advertising While concerns about the inefficiency of governments have merit, Canada, which emphasizes cost effectiveness as part of its strategy, appears to do more than pay lip service to market-based incentives. First, while not explicitly stated, the competitive bids for advertising apply the market-based thinking that increased competition, in this case for public advertising projects, tends to put downward pressure on prices and upward pressure on quality of service and thereby positive pressure on efficiency and cost-effectiveness for the Canadian taxpayer. Second, the government, with oversight from the PWGSC, also selects the Agency of Record to handle its media buys through a “selective” and “competitive” bidding process that, by centralizing buying authority for all government institutions, tends to ensure the government is able to negotiate volume discounts on bids, which becomes necessary given their scope: one of the most important functions of public advertising involves announcements of tenders for sundry government works projects; in 2006, these tenders, which catalyze the competitive bidding process for government projects, led to $14 billion (13.67 billion USD) in contract awards.73 Finally, by creating a public advertising policy that is transparent, the Government of Canada strengthens consumer confidence and diffuses important information that the public needs in order to make informed decisions about finances, health, and the environment.
Public Advertising Institutions of Note The Canadian system has related significant elements of note. First, it has an Advertising Management Information System (AdMIS) that, managed by PWGSC, enables departments to
72 73
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 36
access public advertising information and also fully tracks Government of Canada advertising activities, including project information and expenditures, throughout the life cycle of each initiative.74 Second, Canada has an electronic tendering service called MERX, used by the government to post searchable procurement notices and bid-solicitation documents for access by suppliers and contract officers.75 Third, Canada has a formal government request for proposal document (RFP), posted on MERX, through which advertising services suppliers are invited to submit proposals for government projects.76 Fourth, Canada mandates advertising branding, meaning that institutions must use the “Canada wordmark” when identifying their participation in a collaborative arrangement to enable public recognition of the contributions of the Government of Canada.77 Fifth, Canada has a “one-stop service delivery network,” called Service Canada, that “offers citizens quick access to all Government of Canada programs” through 1-800-O-Canada, on the Web, and through physical points of service.78 Sixth, Canada’s Library and Archives Act requires all institutions to deposit all newly published materials in various formats with the library and archives of Canada, the permanent repository of the government and its institutions.79 Seventh, PWGSC offers trainings for all employees with staff, academics, industry experts, and media associations in aspects ranging from the full fundamentals of government advertising to more advanced concepts, such as campaign analytics, with the implied objective of ensuring government advertising is current and effective.80
Conclusion Geographically, Canada is over 212 times as large as Bhutan, its population, though small at 33,311,40081 is almost 50 times Bhutan’s, and it has a literacy rate of 99 percent, over twice as high. Canada is also historically secular, has an inveterate parliamentary system, a welldeveloped infrastructure, per-capita GDP 8 times greater than Bhutan’s, and approaches government advertising through a lens influenced by Western politics, values, and culture.82 So,
74 75
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 76 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 77 http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 78 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 79 http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 80 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 81 http://www.google.com/publicdata?ds=wbwdi&met=sp_pop_totl&idim=country:CAN&dl=en&hl=en&q=population+of+canada 82 https://www.cia.gov/library/publications/the-world-factbook/geos/ca.html 37
while useful in an abstract analysis of public advertising policy, clearly Canada’s policy is imperfect and somewhat elaborate for a smaller nation like Bhutan. Policy recommendations must therefore lend themselves to adaptation for existing entities to adjust to new responsibilities, and as with any significant policy initiative, implementation must incorporate certain cultural and pragmatic considerations to minimize potential resistance and mitigate or at least phase in the growing pains to existing practices. That said, however, the critical principles of separation of political and economic interests that removes the political benefit of misappropriating government advertising monies, its two national languages (French and English), which can inform Bhutan’s desire to offer advertisements in two languages (English and Dzongkha), as well as a reviewable openness of information remain at the core of any attempt to ensure a principled independence and integrity in Bhutan. 83,84 By Rob Grabow [email protected]
83 84
Sally Young Interview, Barbara Magid. http://www.google.com/publicdata?ds=wbwdi&met=sp_pop_totl&idim=country:CAN&dl=en&hl=en&q=population+of+canada 38
Public Advertising Case Study 3: India
Executive Summary The rationale behind government advertisement in India functions upon the premise that in a democracy, the government has to ensure that its policies and programs are properly presented and correctly interpreted through the press and other media to the people on whose support and goodwill it holds office.85
Introduction to India’s Advertising Policy Government advertisements in India are not meant to be a source of financial assistance to any publication or media outlet. To this end, no advertisements are issued as a matter of routine but only when the need or occasion arises.86
A total number of 11,551 government advertisements were released to various newspapers throughout India during the financial year 2009–10. The government spent 244,13,000 rupees (approx. 536,000 USD) on these advertisements. This was supplemented by advertisements on radio, television, and other forms of publicity like door-to-door campaigns, outdoor boardings, and exhibitions. Expenditure on audio-visual publicity was Rs. 170,00,000 (approx. 373,093 USD). This included approximately 95,06,914 outdoor displays and 80,000 copies of printed material, like speeches of the prime minister, calendars, and other government publicity literature.87
The process of government advertising in India is a complex one with multiple checks and balances at every stage; from the decision of creating an advertisement to the actual placement of the ad and measuring its impact.
The relationship between the Indian government and the media agencies, especially newspapers, is equally complex. Newspapers in India are not subsidized by the government. Government advertisements are not a source of income for newspapers. Instead, the government agencies,
85 86
Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India http://info.pondicherry.gov.in/addraft-1.pdf 87 http://www.davp.nic.in/aenglish0910.pdf 39
such as the Directorate of Advertising and Visual Publicity (DAVP), get advertising rates from these newspapers that are up to 40 percent cheaper than the commercial rates for advertising in the papers. In addition to this discount on advertising rates, the DAVP also gets a 15 percent agency commission from the newspapers.88
Given the lack of subsidies on newsprint as well as the advertising rates that the DAVP commands, the various newspapers associations in India between 2004-2008 rallied to get more concessions from the government. After appointing an independent commission that liaised with Indian Newspapers Society, Indian Federation of Small and Medium Newspapers, Association of Indian Magazines, the Association of Small Newspapers of India, Federation of Small Newspapers, and Indian Language Newspapers Association, the following two changes to the current policy were made:
A stimulus package for print media companies comprising a waiver of the 15 percent agency commission on DAVP advertisements and a 10 percent increase in DAVP rates to be paid as a special relief on loss of revenue in non-governmental advertisements was made. It was also stated that the “pulling power” of the newspaper is an important criterion in evolving a suitable rate for advertisement. While emphasizing pulling power as a relevant factor in determining DAVP advertisement rates, newspapers should also appreciate the fact that government advertisement is a separate category. Apart from having a certain amount of news value, they provide useful information to the reader. Appearance of government recruitment advertisements, for example, in a newspaper add to its pull and prestige and attract a greater readership. A balanced view has, thus, to be taken on this aspect.
It was recommended that the DAVP advertisement rate should consider the following components: • • •
88
Newsprint cost Processing charges Reasonable profit
http://www.davp.nic.in/final_report.pdf 40
• • •
Weightage for small and medium newspapers Pulling power weightage for higher circulation Commission for display advertisements
Even after incorporating the recommendations made, rates for government advertising still remain significantly lower than the commercial rates that the newspapers charge.
Structure India’s advertising policy is set and controlled by the Ministry of Information and Broadcasting (MIB).89 The primary mandate of the MIB is to ensure that all Indian citizens have access to a free flow of information via various media, like radio, TV, the press, publications, advertising and Internet.
The MIB is responsible for setting up a policy framework that allows a healthy development of various mass media in the country and formulating the policy for dissemination of information.90 Its main functions are:
• • • • • • •
News services through All India Radio (AIR) and Doordarshan (DD) for the people Development of broadcasting and television Import and export of films Development and promotion of the film industry Organization of film festivals and cultural exchanges Advertisement and visual publicity on behalf of the Government of India Handling of press relations to present the policies of the Government of India and to get feedback on the government policies
• •
Administration of the Press and Registration of Books Act, 1867 in respect of newspapers Dissemination of information about India within and outside the country through publications on matters of national importance
“Ministry of Information and Broadcasting, Government of India,” last updated on January 2010 http://india.gov.in/outerwin.php?id=http://mib.gov.in/ 90 Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India. 41
89
•
Research, reference, and training to assist the media units of the ministry to meet their responsibilities
•
Use of interpersonal communication and traditional folk art forms for information/ publicity campaigns on public interest issues
•
International cooperation in the field of information and mass media
Based on these functions, the MIB is further subdivided into independent divisions. Government advertising and public service messages are largely under the purview of two main departments—the Directorate of Advertising and Visual Publicity and the Directorate of Field Publicity. Other departments, like All India Radio, Doordarshan, the Publications Department, and Press Information Bureau, also handle some specialized aspects of government advertising.
Directorate of Advertising and Visual Publicity Function. The Directorate of Advertising and Visual Publicity (DAVP) is the multi-media advertising agency of the Government of India.91 It caters to the publicity requirements of different ministries, departments, public sector undertakings, and autonomous bodies of the government of India.92
Structure. The DAVP has different departments dealing with the varied publicity needs of the ministries. Some of its subdivisions are the campaign wing, advertising wing, printed publicity wing, and audio-visual wing. Every government department that needs to advertise can approach the DAVP with its requirements. The DAVP then provides free design advice and helps the client to select the appropriate medium for publicity. The guiding principle for selection is maximum reach with minimum cost. The DAVP empanels various advertising agencies to assist with this process. In certain cases, the DAVP also has the right to advertise proactively based on its mandate.
Selection Criteria. The selection of newspapers/journals that will receive government advertising is made by DAVP. It empanels newspapers based on the guidelines laid out in the Advertisement
91 92
Ministry of Information and Broadcasting, “Outcome Budget 2009-2010,” Government of India, New Delhi. Directorate of Advertisement and Field Publicity. 42
Policy of the Government of India and negotiates a contract rate—for both classifieds and advertisements—with them on behalf of the government. More than 2500 newspapers/journals in Hindi, English, and other regional languages are on DAVP’s panel. Certain regional language publications get concessions in terms of required circulation, number of years of existence and so on to promote growth and development of regional newspapers.93
Other Relevant Information. The ministries and other government departments are entitled to advertise through other agencies not affiliated with the DAVP. However, these agencies need to offer rates similar to the ones that DAVP does. However, in most cases, that is not possible since the DAVP can bargain for the most competitive rates.
Accountability. DAVP activities fall under the Indian government’s Right to Information Act. Any citizen of India is entitled to request the DAVP documents for perusal and questioning. If a citizen or any party interacting with DAVP has a complaint, there is a grievance redressal office in charge of addressing and resolving the problems. The DAVP also maintains a Citizen’s Charter—both in print and online—that highlights the mission, vision, and activities of DAVP. It also produces an annual report of its activities that is available on the Website.94
Mass Mailings The Mass Mailing Department maintains lists of the addresses of 151,00,000 citizens of India. These are further subdivided by area of information being mailed out. Recent topics on mass mailing lists include the speeches of the current prime minister of India (mailed out to heads of schools and universities, all local libraries, voluntary organizations and newspaper editors), information regarding the government’s Family Welfare Program (mailed out to health workers, heads of NGOs working in the field of health, and so on).
The mass mailing wing is under the guidance of DAVP. The mass mailers include advertisements through flyers or other printed literature pertaining to government policies, programs, and achievements of central government and can include photographs of the prime
93 94
“Citizen Charter, Directorate of Advertising and Visual Publicity,” http://www.davp.nic.in/citizen_charter.htm DAVP Handbook. 43
minister and president. It distributes publicity material on the basis of instructions from the client department or as per the needs to the campaign.95 In order to ensure that this form of advertising is not misused, mass mailing is suspended once the Lok Sabha (Lower House) is dissolved up until the next elections are held.96
Mass mailing is a powerful advertising tool as it allows the government to customize the messages according to the population targeted. In a country with immense socio-economic disparities, this becomes a much more effective way of achieving impact than a general advertisement.
Directorate of Field Publicity The main objective of Directorate of Field Publicity (DFP) is to disseminate information about the government’s policies and schemes among the masses. The DFP also generates awareness about health, national integration, and other social issues among the target groups, mostly in remote places.97 The budget for the DGP during 2008–2009 was Rs. 149,00,000 (approx.. 327,005 USD), which was broken down into actual publicity materials, training workshops for employees, and purchase of new hardware, like projectors, computers, and other necessary equipment.98
A few examples of recent publicity campaigns by the DFP include a drive to get people out to immunization booths during the Pulse Polio campaign, a special publicity campaign on iodine deficiency disorder and its control measures, a drive to increase awareness in rural areas about the government’s rural schemes and programs, and several other initiatives.99
The DFP works at a more grassroots level in comparison with other departments under the Ministry of Information and Broadcasting. Equipped with men and material suitable for the job of delivering messages at the doorsteps of the people at the grassroots level, DFP field units
95 96
http://www.davp.nic.in/pdguidelines_new.pdf Ibid. 97 Ibid. 98 Ministry of Information and Broadcasting, “Outcome Budget 2009-2010,” Government of India, New Delhi. 99 Directorate of Field Publicity, “Monthly Highlights Report, February 2009,” Government of India. 44
endeavor to expose the masses to “the diverse socio-economic and cultural milieu of the country and inspire them to move ahead as citizens of the largest democracy in the world.”
The DFP also collects information/people’s reactions to the advertisements and conveys them back to the government. It is engaged in the task of publicizing various programs and policies of the government with its network of 207 Field Publicity Units and 22 Regional Offices.100 Broadly, the aims and objectives of the DFP are: • To project the policies and programs of the government by bringing its men and material face to face with the people and to inform them about the plans and schemes formulated for their benefit. • To educate people about the fundamental national values, like democracy, socialism, and secularism, and to reinforce their faith in them through constant personal contact. • To establish rapport with the people at the grassroots level for their active participation in the developmental activities as also to mobilize public opinion in favor of implementation of welfare and developmental programs. • To gather people’s reactions to the programs and policies of the government and their implementation down to the village level and to report them back for appropriate action by the government. The directorate thus works as a two-way channel of communication between the government and the people.
The DFP not only serves the needs of various ministries and government departments but also works with international organizations such as UNICEF, WFP, and so on. It does not charge for its services but is allocated funds directly through the government budget and occasionally supplements this with fundraising events.
In 2008–2009, the DFP had organized 10,502 special publicity campaigns, showed 34,060 public service films, and arranged 23,512 outreach tours to remote areas in the country.101
“Directorate of Field Publicity, Ministry of Information and Broadcasting,” http://india.gov.in/outerwin.php?id=http://dfp.gov.in/ 101 Directorate of Field Publicity, “Review of Past Performances,” Government of India. 45
100
Publications Division The Publications Division is one of the largest publishing houses in the country. It is primarily concerned with preserving national heritage and disseminating information through the production and sale of low priced, quality reading material on subjects of national importance. Most of the books it publishes are on topics that are not covered by other commercial publishing houses.102
However, besides books, the Publications Division brings out twenty-one journals on issues of national importance and social purpose, which are relevant to public service advertising and also occasionally carry tender notices and other government advertisements. Some of the key examples are the following.
Ajkal, the prestigious literary magazine in Hindi and Urdu, brings out a number of special issues and covers different aspects of Indian culture and literature. Ministries that are connected with these topics—like the Tourism Ministry—use this as a platform to advertise. Yojana, the flagship journal of the division, seeks to carry the message of planned development to all sections of society and serves as a forum to promote a healthy discussion representing a cross-section of views on socio-economic aspects of development. Yojana, which is published in thirteen languages, presents an all-India perspective while highlighting regional development, innovations, and initiatives.
Kurukshetra, the journal on rural development is serving as a forum for exchange of ideas on programs, policies, and implementation status of development efforts in the rural sector. Fertilizer subsidies, rural infrastructure projects, and other similar matters are advertised in such publications.
Employment News/Rozgar Samachar, published in English, Hindi, and Urdu every week is the largest circulated career guide in India. It carries information about job vacancies in central/state
102
Ministry of Information and Broadcasting, “ Outcome Budget 2008–2009,” Government of India. 46
government departments, public sector undertakings, educational institutions, and reputed private organizations. Its editorial pages include a lead article, diary of events, letters to the editors, quotations, articles on the world of science, besides those on career guidance and other matters of use to examinees.103
The books and journals are sold through dedicated shops called “Sales Emporia” in major cities, like Mumbai and New Delhi.104
To keep pace with technology, Publications Division is now starting to publish online. Employment News has also launched an interactive career oriented Website under the domain www.employmentnews.gov.in. The Website has a page hit of more than 3,00,000 users per day and a budget of Rs. 6,00,000 (approx. 13,168 USD) annually. They also try to provide erecruitment solutions through an interactive Website.105 The government policy on advertising online is still in an early stage. On the one hand, the Indian government struggles with defining Internet censorship and on the other with preserving democratic values.
Press Information Bureau The Press Information Bureau (PIB) is the agency of the Government of India to disseminate information to the print and electronic media on government policies, program initiatives, and achievements. It has a budget of approx. Rs.1628,00029 (approx. 3,572,923 USD). Functioning as an interface between the government and the media, PIB also provides feedback to the government as reflected in the media.106 It is responsible for the brand management of the Indian government via press releases and features, press briefings, press conferences, and conducted tours.
“Publications Division, Ministry of Information and Broadcasting,” http://publicationsdivision.nic.in/emp_show.asp?id=1 104 Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India. 105 “Citizen Charter, Publications Division, Ministry of Information and Broadcasting,” http://publicationsdivision.nic.in/others/citizen-charter.pdf 106 http://www.indiaprwire.com/misc/pib.htm 47
103
The PIB also accredits Indian and foreign media representatives, news cameramen, and technicians. In March 2009, 1,586 correspondents and 474 cameramen were accredited by the bureau’s headquarters besides 152 technicians and 85 editors/media critics.
All India Radio All India Radio covers 99.14 percent of the population and 91.79 percent of the area of the country with 231 broadcasting centers and 372 terrestrial transmitters, including 170 FM transmitters in twenty-four language and 146 dialects nationally. Its primary role is of a national public service broadcaster. It is mandated to pay special attention to niche areas of the governmental agenda. Some examples are the fields of education and spread of literacy, agriculture, rural development, environment, health, and awareness about women’s issues. Amongst all the different departments under MIB, radio (AIR) and television (Doordarshan) are the two that focus more on promotion of culture and ideals. The messages are crafted with the intention of promoting national integration and harmony, fight social evils, and impact social transformation. “Bahujana Hitaya, Bahujana Sukhaya,” i.e., to promote the happiness and welfare of the masses through information, education and entertainment is the main mission of AIR.
Tenders All government contracts are advertised as tenders in the open market in India. Each ministry or department is expected to follow detailed guidelines in inviting contractors to bid. The MIB assembles all tenders from various ministries and makes them available online. A special Website has been created that can be accessed by vendors globally. Each ministry also advertises —via DAVP—tenders in regional and national newspapers as per requirements. Tenders are published in both English and Hindi and occasionally also in a regional language to ensure fairness and maximum reach.
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Incredible India The “Incredible India” campaign, launched in 2002, was a major initiative by the Government of India, to promote India as a tourist destination.107 It is a notable example of the Indian government’s international advertising campaign.
Critiques Although there are several positive aspects of the Government of India’s media policy, there are several cautionary tales as well.
The Ministry of Information and Broadcasting suffers from the same bureaucratic problems that plague the rest of India’s massive governance machinery. First, bureaucratic functions of many departments often overlap, leading to repetition of work and redundancy of positions. Second, this redundancy and bureaucracy leads to lack of accountability and inferior work.
The outcomes of lapses due to bureaucratic departments can be demonstrated by the two recent mistakes in government advertising. The first was when the advertisement for Indian Railways showed Delhi as being a part of Pakistan. The second was the Incredible India campaign ad that showed an African elephant in an Indian biodiversity advertisement.108
Although sound policies might be in place, the mechanisms to measure the impact of these policies are not clearly laid out. There is no cost-benefit analysis undertaken to measure the impact of media spending. Hence, the changes in governmental policy are not made on an incremental basis after regular feedback but are made in a more ad hoc manner.
In certain cases, there are no clear guidelines set or distinctions made on certain policy clauses. For example, ownership requirements of media (Indian vs. foreign) for empanelment with DAVP is not articulated in any of the organization’s materials.
http://www.icmrindia.org/casestudies/catalogue/Marketing/MKTG122.htm Priscilla Jebaraj, “African jumbo in Incredible India Ad,” http://www.thehindu.com/news/national/article799389.ece
108
107
49
The DAVP has also been criticized for using public funds to aggrandize historic political figures. In selecting these figures, no rationale has been provided or set process defined. Often the political party in power seems to influence the selection, which can lead to distortion and manipulation of public opinion. A recent example showed that the DAVP has spent nearly Rs 3 crore (approx. 600,000 USD) over a period of two months on advertisements to glorify late prime minister Rajiv Gandhi as against only Rs 87 lakh (approx. 175,000 USD) over a period of ten years for former Lal Bahadur Shastri, who enacted far more legislation in India.109 These full-page newspaper advertisements—usually bearing a photograph of Mr. Gandhi—do not carry any public service message, are not commemorating any occasion (his birth date, death anniversary, or something similar). They are simply the creation of idols in print. Since there were no set guidelines for media spending, the DAVP is not immune from pressure by its political masters.
In summary, for any policy to be effective, the loop needs to be closed. Strategy needs to be followed by action, measurement of impact, feedback, and restructuring of strategy.
Conclusion India is the world’s most populous democracy and South Asia’s dominant economy. The combination of its unique demographic makeup, political system, and colonial history makes it the ideal nation-state for Bhutan’s nascent democracy to emulate.
The Royal Government of Bhutan (RGoB) maintains strong ties with the Government of India (GoI); Indian military bases within Bhutan provide security; the Indian government covers Bhutan’s budget deficit; India is Bhutan’s largest trading partner and accounts for 98 percent of its exports and 90 percent of its imports;110 and the Bhutanese Ngultrum is pegged to the Indian rupee, with rupees in free circulation in Bhutan.111
109 110
Press Trust of India, “3 Crores in 2 Months for Rajiv Gandhi Ads,” NDTV, Friday January 29, 2010, New Delhi. Jay Shankar and Bibhudatta Pradhan, “Singh Visits Bhutan to Show India Backs Its Democratic Changes,” Bloomberg News, May 15, 2008. 111 “CIA World Factbook – Bhutan,” https://www.cia.gov/library/publications/the-world-factbook/geos/bt.html 50
As such, the GoI’s advertising policies offer a relevant template for the RGoB to formulate an advertising policy unique to Bhutan’s needs.
As Bhutan embarks on a development program fueled by hydropower exports, the RGoB can learn from the methods used by the GoI to adapt its advertising policy to a similar economic expansion that India has recently experienced. India can also offer lessons on pitfalls to avoid while formulating policies—the GoI’s media strategy seems to be heavily influenced by a political structure built on a patronage system. This system seems to breed corruption and inefficiencies. Being a nascent democracy, Bhutan can install the checks and balances now to avoid such disastrous outcomes in the future. By Sankalpa Dashrath [email protected]
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Public Advertising Case Study 4: South Africa
Executive Summary South Africa’s transformation into a democratic state in 1994 provided the opportunity and challenge for President Nelson Mandela to unify a country that had been divided along racial lines for forty-six years. Since then, South Africa has consciously worked to improve communication between the government and rural and underserved populations. Awarding government grants to media outlets that promote diversity and facilitate communication with underserved populations has been a success; however, their attempts to subsidize the press through advertisements has failed because of the propensity of corruption by government officials.
Media and Advertising Policy The Government Communication and Information System (GCIS) directs government media, and adverting policy is directed by it. Its purpose is to provide a “comprehensive communication service on behalf of government to facilitate the involvement of the majority of South Africans in governance, reconstruction and development, nation building and reconciliation.”112
Their main work consists of: serving as a media liaison and coordinating the media strategy across the government, monitoring domestic and international media coverage of government policies and programs, providing both in-house communication services and outsourcing where appropriate, marketing South Africa internationally, promoting local media development and diversity, producing magazines on socio-economic issues, and other opportunities.113
South Africa produces most of its government advertisements in-house through the Communication Service Agency (CSA). In 2008/2009, the government spent 20.8 ZAR or (2.9 million USD) on advertising. The CSA is specifically tasked with: 1. Creating advertisements. The CSA is tasked with marketing, product, and content
development. The CSA’s budget for 2008–2009 was 41,385,000 ZAR (6,108,036 USD) Their
112 113
http://www.treasury.gov.za/documents/national%20budget/2010/ene/vote08.pdf Ibid. 52
marketing section manages government’s corporate identity; develops strategies for marketing campaigns, events management, public relations campaigns and advertising; manages government’s communication distribution network; and provides a media bulk buying service. According to the GCIS, the focus of government advertising and campaigns “should be on messages that enable the public to participate in democracy and improve their lives.” While crafting campaign messaging, the heads of communication (HoCs) must abide by the following guidelines: a) promote behavior or attitudes that are generally regarded as being in the public interest, i.e. that will lead to improved public health and safety or quality of life b) promote public awareness and compliance with legislation c) raise awareness of government services available to the public or target audience d) encourage public use of government products and services e) promote public awareness of rights, responsibilities, duties or entitlements f) encourage public involvement in government decision-making g) inform the public of new, existing or revised government policies, programmes, initiatives or events h) promote public well-being, safety and order in the event of a crisis or emergency i) report on government performance in service delivery to facilitate accountability to the public j) encourage community pride, spirit, tolerance or assist in the achievement of a widely supported public policy outcome k) recruit staff, publish important statutory information and promote business opportunities with the department concerned.114
As for what not to do, the GCIS specifies that public advertisements must not: refer to any political party, use any political slogans, or promote any one individual (such as a minister).115 Each department has an HoC who is responsible for the implementation of marketing and advertising campaigns and must follow the guidelines dictated by the GCIS. All departmental
114 115
http://www.gcis.gov.za/resource_centre/guidelines/comm-pol-guide2010.pdf, 12. http://www.gcis.gov.za/resource_centre/guidelines/comm-pol-guide2010.pdf, 14. 53
marketing campaigns must be based on a GCIS-approved marketing strategy. While creating a media strategy, the HoC will consult with the GCIS as they have a database of appropriate agencies. A copy of the approved campaign marketing strategy must be submitted to the GCIS at least ten working days prior to the planned implementation for multimedia advertising campaigns exceeding 1 million ZAR (143,113 USD), and at least two working days for standard advertising campaigns.116 During this time, the departments must not commit to any costs or obligations in terms of the proposed campaign until it has received written approval of the marketing strategy from the GCIS. “The right of final approval for media placement and campaign content rests with the GCIS, which will take all aspects addressed in these policy guidelines into careful consideration when assessing the suitability of departmental marketing campaigns for implementation.”117 This process places a lot of power in the GCIS. As such, it is important that the GCIS be comprised of a diverse body of individuals, who are not susceptible to political whims.
In 2010, the GCIS was further tasked with crafting communication to speed up “economic growth, improve the health profile of all South Africans, intensify the fight against crime and corruption, and boost international cooperation by supporting communication about international forums.”118 As this has just been mandated by the government, it is unknown whether or not they have accomplished these goals yet.
Development and Empowerment of Local and Rural Communities Since 1994, the South Africa government has made a concerted effort to improve the economic standing of formerly impoverished communities. Many of the poorer communities are in rural areas with little access to media and government resources. As a result, the GCIS has created several initiatives to improve their ability to access information and government services: the Media Development and Diversity Agency, Thusong Service Centers and the Vuk’uzenzele Magazine.
116 117
http://www.gcis.gov.za/resource_centre/guidelines/comm-pol-guide2010.pdf, 13. Ibid. 118 Ibid. 54
Media Development and Diversity Agency (MDDA) Local media was strengthened in 2003 through government and private sector partnership known as the Media Development and Diversity Agency (MDDA). The MDDA was formed to create an environment for media development and diversity that is conducive to “public discourse and which reflects the needs and aspirations of all South Africans; redress exclusion and marginalization of disadvantaged communities and persons from access to the media and the media industry; promote media development and diversity by providing support primarily to community and small commercial media projects.”119
The MDDA defines community media as “any media project that is owned and controlled by a community where any financial surplus is reinvested in the media project.”120 The MDDA fund projects that add to media diversity are sustainable, promote a culture of reading, and involve the community.121 Since inception in 2004, the MDDA has supported more than 323 community and small commercial media projects (both broadcast and print), with approximately more than R118m in grants.122 It should be noted that this is six times more than the government expenditure on advertising, exemplifying the government’s commitment to the development of underserved communities.
A nine-person board runs the MDDA. The president, on the recommendation of the National Assembly, appoints six members, and the law mandates that the public be involved in the nomination process. One can see calls for nominations on their Website once terms are over; the short-listed candidates are published as well. They are nominated on the principles of fairness, freedom of expression, openness, and accountability; and they must uphold the Constitution and the other laws of the republic. Three members are appointed by the president, of which one must be from the commercial print media and another from the commercial broadcast media.123 With such an open and inclusive board, the awarding of grants has become less susceptible to political manipulation than the government placement of advertising in the press.
http://www.gcis.gov.za/resource_centre/public_entities/mdda_legislation/a14-02.pdf MDDA application guide. 121 http://www.mdda.org.za/brochure/Brochure(eng).pdf 122 http://www.mdda.org.za/themdda-MediaReleases.htm 123 http://www.gcis.gov.za/resource_centre/public_entities/mdda_legislation/a14-02.pdf, 7.
119 120
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“In a nutshell, MDDA has helped many projects get off the ground and others to survive crises, but medium term sustainability remains a challenge,” said Guy Berger, a board member of the MDDA and the head of the School of Journalism & Media Studies at Rhodes University, Grahamstown. According to Mr. Berger, the African National Congress (ANC), as a party, has urged government to increase funding to MDDA. Mr. Berger further specified that this system is clearly preferable to using advertising as an incentive or a subsidy.124
Thusong Service Centers Thusong Service Centers, formerly known as Multipurpose Communication Centers (MPCCs), are established in local communities across South Africa to provide local residents with information, such as employment opportunities, housing projects, and programs. These centers are another government by the GCIS and are, according their Websites, “one stop centers for services and information.” As of March 2009, 137 Thusong Service Centers were in operation.125 The government’s goal is to establish a Thusong Service Center in each of the 283 local municipalities.126
Thusong Service Centers allow people to access easily government resources and maneuver through government bureaucracies. They are particularly useful in rural areas where distances are vast and travelling to urban centers to get services and information is expensive. For these reasons, Thusong Service Centers have been identified as the main way of implementing development communication.127 Methods to develop communication with poor and rural populations include: government material written in simple language and local languages, alternative methods for those who are illiterate such as drama, and community radio.128 One of the most beneficial outcomes of these centers is that they allow communication to flow two ways, from the government to the people and vice versa.
124 125
Interview with Guy Berger. http://www.thusong.gov.za/about/history/index.html 126 Ibid. 127 http://www.thusong.gov.za/faqs/index.html 128 http://www.thusong.gov.za/faqs/index.html 56
Vuk’uzenzele Magazine In an attempt to increase rural communities’ access to information, the GCIS launched Vuk’uzenzele Magazine in 2005. The GCIS produces and distributes Vuk’uzenzele Magazine twice a month in print, online, and in Braille. It provides citizens with information on socioeconomic and other opportunities and how these can be accessed. It has a print order of 1.6 million copies, which are circulated in all nine provinces, in large part door-to-door in deep rural, rural, and peri-urban areas. The magazine is published in all official languages, but the majority of the print-run is in English. In the year 2010, 4.7 million USD was allocated. Content includes “practical information on how to access and make use of socio-economic opportunities, government campaigns and programs, local government issues, community development initiatives and light, entertaining features.”129
Advertising Regulators Advertising in South Africa is self-regulated.130 The Advertising Standards Authority of South Africa (ASA) handles complaints about advertising that is considered to be unethical, untrue, or misleading.131 The primary purpose of the ASA is the regulation of commercial advertising, but it also applies “to advertisements by government departments and agencies and to those by other non-commercial organizations and individuals.”132
The ASA is an independent body set up and paid for by the marketing communication industry itself to ensure that its system of self-regulation works in the public interest. The ASA has a president independent from the industry. According to the ASA’s Website, “Advertising is a service to the public and, as such, should be informative, factual, honest, decent and its content should not violate any of the laws of the country.”133
As to what the ASA means by self-regulation, it states, “the three parts of the industry—the advertisers who pay for the advertising, the advertising agencies responsible for its form and
http://www.info.gov.za/vukuzenzele/ Adrian Hadland, Wesley Cowling & Bate Felix Tabi Tabe, Advertising in the News. (Cape Town, South Africa: HSRC Press, 2007) p 1. 131 http://www.ombudsman.org.za/content/default.asp 132 http://www.asasa.org.za/Default.aspx?mnu_id=13 133 http://www.asasa.org.za/Default.aspx?mnu_id=10#Rulings
130 129
57
content, and the media which carry it—work together, to agree advertising standards and to set up a system to ensure that advertisements which fail to meet those standards are quickly corrected or removed.”
Though the ASA code calls for the labeling or identification of paid-for content, so as to not mislead the viewer/reader, these aspects are rarely enforced, especially in print media. If and when the line is blurred, people must submit formal complaints; however, this rarely happens.134 This dependence on complaints can be seen as a weakness or a strength. The ASA places the onus on the people to complain, and thus it necessitates an active and involved citizenry. In places where the population is illiterate or uneducated, this type of regulation would be ineffective. One problem with some print advertising in South Africa—as in many countries—is that the ads often look like regular content. Though some do use labels such as “Special,” “Advertorial,” or “Commercial Feature” to indicate to the reader when he/she is looking at an ad, sometimes it is not clear. For example, labeling a section “Special Feature” can be confusing to readers.135 As for government advertisements, they are always accompanied by a governmental logo.
According to ASA’s 2006–2007 annual report, only 1 percent of the 2,095 complaints were lodged against government advertisements.136 This shows that the GCIS has done a good job at vetting government advertisements and campaigns organized by the various government departments (or that people don’t bother, don’t know how to complain or didn’t realize something was amiss).
Problems with Government Advertising in the Press There is debate in South Africa media about the benefits and weaknesses of government support of the media. Some see the government as intrusive, reducing media’s independence; others view
134
Adrian Hadland, Wesley Cowling & Bate Felix Tabi Tabe, Advertising in the News. (Cape Town, South Africa: HSRC Press, 2007), 2. 135 Ibid. 136 http://www.asasa.org.za/ClientFiles/Pdf/ASA%20Annual%20Report_2007_2008.pdf, 18. 58
government involvement as helping build a united, inclusive nation around common values.137 What resounds through the debates is that government advertising is not the preferred way to subsidize the press.
One such critic, Guy Berger, chairperson of the board of a local newspaper, the Grocotts Mail, said, “Personally, I do not believe governments should use advertising as a tool for media support (or punishment).” Mr. Berger’s opinion stems from his experience at the Grocotts Mail where a local municipality boycotted the newspaper after unhappiness with coverage in 2007/2008. The newspaper is based in Grahamstown and has a readership of about 24,372 per week.138 For the duration of the boycott, communication between journalists and local government officials became somewhat hostile. The real victims were the people living in the communities as reports were often devoid of government official’s explanations. For example, journalists had more difficulty contacting government officials when reporting on various government services such as toxic water crises, power outages, dumping, and sanitation. During this time, the municipality would often decline to comment.139
This was not the first occasion that the government boycotted or threatened to boycott newspapers. Former Minister in the Presidency Essop Pahad threatened to exclude the Sunday Times from state advertising.140 Additionally, in 2008, the Dlambe municipality stopped advertising in Port Alfred’s weekly Talk of the Town (TotT) after it published a story in May about the municipality dipping into its “Pothole Fund” to pay for a new luxury mayoral car.141 As for the Grocotts Mail, they did not sit back quietly. They legally challenged the municipality on several counts:
http://www.wolpetrust.org.za/dialogue2003/DN102003duncan_paper.htm http://www.grocotts.co.za/ads 139 http://www.journalism.co.za/index.php?option=com_content&Itemid=100009&catid=165&id=1067&view=artice 140 http://nml.ru.ac.za/blog/guy-berger/2008/10/24/resources-about-government-advertising-boycotts-private media.html 141 http://nml.ru.ac.za/files/Advertising%20boycotts%20hit%20two%20local%20papers.pdf
138
137
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•
Violation of the Constitution: sections 16 (free expression); 7.2 (obligation to uphold rights); 152 and 195 (democratic, accountable and participative local governance);
•
Violation of Municipal Systems Act (responsiveness, communicative, participative governance), and violation of Municipal Finance Management Act (supply chain management procedure); and Promotion of Administrative Justice Act (procedural fairness; good faith, good reason).142
•
With the possibility of going to court, the municipality backed down, resumed advertisements, and agreed to pay for all the legal costs of the Grocotts Mail.
According to Mr. Berger, the local municipality “is dominated by ANC party members, but there is nothing in the ANC’s media policy that proposes advertising as a political weapon. Instead, the party calls for engagement with the media.” Rather than using advertising as a political weapon, Mr. Berger, suggested the government use “self-regulatory bodies such as the Press Council to which complaints can be taken; the right to sue for defamation; the MDDA to promote more media at grassroots;”143 or approaching the Press Ombudsman.144 Tenders In South Africa, public sector procurement or government procurement is estimated to amount to approximately 14 percent of gross domestic product (GDP) (R 475.8 billion/68.35 USD in 2006/07), which amounts to about 9.56 billion USD.145 The South African Constitution provides that when organs of state procure goods or services, they must comply with five principles: fairness, equity, transparency, competitiveness, and cost-effectiveness.146 South Africa employs a policy of affirmative action to blacks in an effort to improve their economic status.147
A branch of the GCIS, known as the Supply Chain Management and Auxiliary Services, manages all government tenders, and all available bid opportunities above 500,000 ZAR
http://nml.ru.ac.za/files/Grocotts%20article%20in%20Sunday%20Times%2020%20Sept%202008.pdf http://nml.ru.ac.za/blog/guy-berger/2008/10/24/resources-about-government-advertising-boycotts-privatemedia.html 144 http://nml.ru.ac.za/files/Grocotts%20article%20in%20Sunday%20Times%2020%20Sept%202008.pdf 145 http://www.puk.ac.za/opencms/export/PUK/html/fakulteite/regte/per/issues/2006_2__Bolton_art.pdf 146 Ibid. 147 Copyright 1997 The PRS Group, Inc. The PRS Group / Political Risk Service November 1, 1997
143 142
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(~$74,000 USD) are published to its Website in a weekly bulletin every Friday.148 The subscription rates for the “Government Tender Bulletin” are R39.32 (5.63 USD) per annum and R45.99 (6.58 USD) per annum overseas.149 Rather than have sporadic tender placement, the weekly bulletin and subscriptions provide a central place where anyone can access it.
Naturally, there will be corruption. One of the most recent scandals involves ANC Youth League president Julius Malema. Citing official tender and government documents, the Sunday Times reported that Malema’s companies were awarded more than twenty contracts, each worth between R500 000 and R39m between 2007 and 2008.150 One of the companies, a small engineering firm, profited from more than R130m (18.6 million USD) worth of tenders in just two years. Mr. Malema then used these profits to pay for his luxurious lifestyle, particularly to finance two opulent homes. Malema’s case is still being investigated.151 In order to curb tender fraud, such as Malema’s, in public procurement, Minister of Finance Pravin Gordhan proposed levying penalties of up to double the value of a contract on those who obtain contracts fraudulently. In October 2010, he announced that the government was investigating a total of R25 billion (3.5 billion USD) of procurement and tender fraud.152 According to South Africa’s Government Website, other measures to curb tender fraud include: • • • Making public officials who assist in tender fraud liable for the resulting losses incurred by the government. Implementing measures to ensure that officials who have breached the buying rules remain under suspension while an investigation into them is under way. Revising procedures for the issuing of tax clearance certificates, so that the South African Revenue Service (Sars) can more easily check whether a bidder has the required tax compliance or not. Strengthening tax compliance measures associated with government procurement,
•
148 149
http://www.gcis.gov.za/aboutus/procurement/index.html http://www.info.gov.za/view/DownloadFileAction?id=133389 150 http://www.news24.com/SouthAfrica/News/Malema-profits-from-govt-tenders-20100220 151 http://www.mg.co.za/article/2010-06-28-malema-tender-probe-still-not-concluded 152 http://www.southafrica.info/business/economy/policies/minibudget2010d.htm 61
including the introduction of a withholding tax on payments made to businesses selling to the government.153
As these proposed changes were announced on October 27, 2010, it is still too soon to tell whether or not they have been effective. Despite this, it is important to note that the media was free and active in their reporting of Mr. Malema’s corrupt activities. However, if they had been funded through government advertisements, they may have been less inclined to report on them for fear of the government pulling out advertisments. The media’s independence from government advertising money has helped them increase government transparency by holding it accountable.
Branding South Africa As a fairly young democracy, South Africa is concerned about its image. According to the former minister in the presidency, Essop Pahad, in 2005, One of the greatest challenges South Africa has faced since we achieved freedom has been to engage with the international community on terms that promote our national interests … From a communications perspective, that has brought the challenge of closing the gap between negative perceptions of our new democracy and the reality of a country steadily undergoing reconstruction and development.154
The International Marketing Council of South Africa (IMC) was established in August 2002 by the GCIS to help create a positive and compelling brand image for South Africa. The GCIS, along with the South African Tourism and The Department of Trade and Industry, fund the IMC.155
From 2002 to 2005, the IMC has created 7,000 radio advertisements, which have reached 94 percent of South Africa’s adult population, and over 560 television advertisements.156 They
Ibid. Africa News April 17, 2005 Sunday South Africa; Positive Image of Our Country Crucial, Says Pahad. (http://allafrica.com/stories/200504180532.html) 155 http://www.brandsouthafrica.com/who-we-are/427-stakeholders.html 156 Africa News April 17, 2005 Sunday South Africa; Positive Image of Our Country Crucial, Says Pahad. (http://allafrica.com/stories/200504180532.html)
154
153
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created the popular advertisement “Today I Woke up in South Africa” and broadcasted it on local television stations. You can view the advertisement online at the following location: http://www.youtube.com/watch?v=0wEYKyK9z64.
The IMC also advertises abroad. In London, they have branded taxis with the “South Africa Alive with Possibility” logo and interesting facts about the country.157 They have created a toolkit filled with materials for people to use when marketing South Africa abroad.158
Ubuntu To help create a South African style of advertising, the country employs the concept of Ubuntu, meaning humanity. Ubuntu is an Africa philosophical concept that has become one of the pillars of South Africa after apartheid. It has played a major part in nation building as it stresses the importance of brotherhood. Nelson Mandela described Ubuntu as A traveler through a country would stop at a village and he didn’t have to ask for food or for water. Once he stops, the people give him food, entertain him. That is one aspect of Ubuntu but it will have various aspects. Ubuntu does not mean that people should not enrich themselves. The question therefore is: Are you going to do so in order to enable the community around you to be able to improve?159 On any given day, more than three thousand commercial messages pass through South Africans’ minds. Jannie Ngwale, executive chairman of the advertising company, The Agency, believes that advertising agencies use Ubuntu when advertising. He said, This is a high point in South African advertising. We have arrived and so has the time; the time when the bulk of our advertising has a distinctly South African flavor; the time where consideration for—and empathy with—the audience creates communication that is deep, insightful, moving and, above all, human. When South African advertising talks with the spirit of (and not just about) Ubuntu, then we can stand proud. Our voice will be more frequently heard and, in this way, we will build a better life for the majority of South Africans.160
157 158
http://www.brandsouthafrica.com/marketing-materials.html http://www.brandsouthafrica.com/component/content/article/20/10-toolkit.html 159 http://www.youtube.com/watch?v=Dx0qGJCm-qU 160 Jannie Ngwale, “Advertising can enshrine Ubuntu,” Sunday Times (South Africa) Economy, Business & Finance, September 25, 2005, 7. 63
Country Background and Conclusion South Africa’s transformation into a democratic state in 1994 signaled the opportunity and challenge for President Nelson Mandela to unify a country that had been divided along racial lines for forty-six years. The task was challenging not only because South Africa is racially diverse, but also because it is linguistically rich. There are eleven official languages, including English, Afrikaans, Sesotho, Setswana, Xhosa, and isiZulu. Though English is most frequently used, according to the 2001 census, isiZulu is the most common home language and is spoken by nearly a quarter of the population. It is followed by Xhosa at 17.6 percent, Afrikaans at 13.3 percent, Sepedi at 9.4 percent, and Setswana and English each at 8.2 percent.161 Total adult literacy is 88 percent.162 The South African media became very important following the fall of the apartheid regime as the radio was used to broadcast the Truth and Reconciliation hearings. Using the African concept of Ubuntu, the Truth and Reconciliation commission called for victims’ families to face government officials who had committed violent human rights abuses against their loved ones in order to preserve the apartheid regime. If the former government official confessed and told the details of his crimes to the victim’s survivors, he would be granted amnesty. Though the process was difficult, it helped South Africans transcend the bitterness, hatred, and suspicion of the past and to make the transition to a more stable—albeit still imperfect—political order.
South Africa is by far Africa’s superpower; however, it still remains rife with problems. Unemployment is high, many South Africans remain poor, and it has the second highest number of HIV/AIDS patients in the world. 163
Though South Africa’s population is roughly seventy times as large as Bhutan, its continued goal to unify a diverse country around shared values such as Ubuntu is similar to Bhutan’s commitment to GNH.
161 162
http://www.southafrica.info/about/facts.htm#languages http://www.unicef.org/infobycountry/southafrica_statistics.html 163 http://news.bbc.co.uk/2/hi/africa/country_profiles/1071886.stm#facts 64
South Africa, like Bhutan is a fairly young democracy, faced with the task of unifying a country. Ubuntu has played a part in helping develop a South Africa style and philosophy to abide by. Though there are no clear policy prescriptions or outcomes from Ubuntu, it is something that is in the minds of marketers and the government when considering how to advertise.
Despite the positive message of Ubuntu, crime, aids, and poverty have made unifying the country difficult. Events like the World Cup helped bring the country together again, and South Africa should continue to ramp up efforts to promote Ubuntu where possible, particularly since the country is so racially, linguistically, and economically diverse.
With regards to government advertising, problems arose mostly in local municipalities. Based on the examples provided, they seem to be more likely to use government advertising as a political tool at a local level rather than at the national level. Fortunately, there were enough checks and balances in place for the newspaper to take action and bring abuses to the public’s eye.
A more effective approach than government advertisements in the media is the process of awarding grants through the MDDA. Not only does this encourage diversity and help start up media outlets, but it also avoids problems that arise from government officials’ political whims. The goal now should be to increase MDDA projects and see how small community projects can become sustainable community staples.
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(Note: Numbers in 2009/2010 are inflated due to the World Cup; as such, refer to 2008/2009 for more accurate numbers.) In 2008/2009, the GCIS spent a total of 20.8 ZAR (2.9 million USD) on advertising.
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By Michelle Moghtader [email protected]
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Public Advertising Case Study 5: United Kingdom
Executive Summary The United Kingdom has an extensive and largely successful public sector—one of the most notable in the developed world. Subsequently, their need for government advertising is much greater and, therefore, more cultivated. The multifarious objectives for their advertising and the ways in which it is achieved can be of great interest to any country developing a government media policy.
The country is recently emerging from thirteen years under the Labour Party (left-of-centre), with a new government led by the Conservative Party (right-of-centre). The current government is in the process of vastly cutting the public sector (with obvious implications on tenders) and, according the Cabinet Office, concurrently cutting government advertising and marketing by half. The previous year, however, under the Labour Party, the government was the UK’s largest advertiser, with a budget of ?500 million (800 million USD).164 Therefore, for the purposes of this report, the majority of the retrospective analysis will predate 2010.
The Digital Age of Tendering According to the treasury, the UK spends ?150 billion (240 billion USD) per annum on public procurement. It is important to note that the devolution of Wales, Scotland, and Northern Ireland from England, means that each of the four countries has its own tendering policies. Furthermore, the European Union laws and opportunities for public procurement also apply—this system is subsequently operating on two levels. The vast majority of information regarding tendering opportunities is to be found on the Internet. Given the often-composite nature of the application process, the Internet has proved to be a successful resource in easily providing guidelines. While technological accessibility or lack thereof remains a hindrance in Bhutan, this mode of dissemination is potentially feasible and advisable for larger, more complex tenders. Such jobs will most likely be offered to bigger, urban-based firms with readily available access to
“Government cuts shadow over ad market,” Financial Times, accessed October 18, 2010, http://www.ft.com/cms/s/0/897eaad0-da11-11df-bdd7-00144feabdc0.html 68
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computers. For public tenders from EU institutions, there is a hardcopy circulation of the “Supplement to the Official Journal of the European Union.” There is also an online version of this publication, entitled Tenders Electronic Daily (to be found at: http://ted.europa.eu/TED/main/HomePage.do). According to the Website, “It is updated five times a week with approximately 1500 public procurement notices from the European Union, the European Economic Area and beyond.” One of the primary advantages of registering with the site and utilizing it (as opposed to the publication) is the efficiency it offers. The site exclusively allows businesses to “access the entire content of TED, including the archive. To personalise search profiles, according to your needs. To get e-mail alerts based on your search profiles.” For local and national tenders, there is much the same system. The primary source of information is the Internet. Each of the four countries’ governments issues its own Website. England has categorized the tenders into smaller contracts—?100,000 (160,000 USD) or less—and larger ones. In this instance, online advertising has proved to be the most efficient and transparent system. There is a Website for the former, defined as a “national lower-value contract opportunity portal” (supply2.gov.uk). For larger public procurement, there is a host of privately owned Websites, supplying information on opportunities—some of which provide hardcopy publications, which one may subscribe to. As part of its transparency efforts, the Office of Government Commerce (OGC has recently been absorbed into the Cabinet Office under the new Efficiency and Reform Group, established by the recently elected Conservative government) provides extensive information on the regulations that frame the tendering process. The space is designed to help suppliers by offering the same information the contractors use during procurement. There is extensive information on “Best Practice Guidance” for all types of contracts. It has been an excellent example of government transparency; as OGC states, “Government has set out the need for greater transparency across its operations to enable the public to hold public bodies and politicians to account. This includes commitments relating to public expenditure, intended to help achieve better value for money.” The subsequent impact on accountability has served to improve quality and “value for money” in the realm of public contracting. This method of dissemination is both highly recommended and easy to execute.
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Furthermore, this serves to open a gap in the market for advertising firms or, more specifically, the private sector to represent the government.
Using Social Media to the Government’s Advantage Policy regarding social media remains more fluid in its evolution, given the recent nature of the medium in comparison to TV, radio, and publishing. The UK government released a guide for its civil servants, irrespective of their department, entitled “Engaging Through Social Media,” produced by the Central Office of Information (COI). First and foremost, the government employees are informed to adhere to basic principles—they are to be “credible, consistent, responsive, integrated, a civil servant.” In elaborating on guidance for press officers, the report informs that they “should evaluate departmental initiatives discussed on social media applications and participate in debate about their organization’s decisions.” This provides a fruitful resource for feedback regarding governmental policy and its efficacy. Agents are told to monitor and evaluate relevant sites that target the departments’ key demographic segment by, for example, gauging “how effectively other sites engage your target audience.” They are to participate personally in order to gain a thorough understanding of how the Websites are used with the subsequent benefit of improving outreach. After cultivating a thorough understanding of a particular social media’s benefits and risks, only then are press officers encouraged to utilize the outlet. This mode of communication can be used for publishing necessary and/or urgent information and responding to questions from the general public. While it is not as feasible to publish longer documents, such as updated legislation, inquiries relating to such matters can allow the press officer to direct the public to alternative media outlets with more in-depth information. This is an example of why the engagement with the public in this capacity is argued to promote transparency.
The Met Office—a governmental department concerned with the weather—has impressively and efficiently optimized its outreach through social media. It has a clearly defined social media policy, which includes Facebook, Twitter, Flickr, and YouTube. Users of such sites, who are members of the Met Office’s “profile,” are informed they will receive between ten and thirty messages per week, the limit of which can be exceeded in extenuating circumstances. The public can benefit for a multitude of reasons. Advertising severe weather warnings, such as floods, can
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serve to help agriculturalists with their crop to save lives. Information on predicted snow levels during the winter has helped prevent motorist emergencies. More recently, Facebook and Twitter were used for statements and releases on volcanic ash: such information was a necessity for the millions of airline travelers affected, along with others dealing with the fallout’s various safety implications.
Furthermore, these outlets can also help refine policy development in all areas of government. Marketers are encouraged to “monitor social media for discussions about [their] organization, its proposals, campaigns, or the services it delivers.” Being able to locate specific demographics through such easily accessible means can be used to the government’s great advantage in measuring the need for certain strategies and the impact of existing policy—not to mention the government’s capacity to advertise campaigns while directing them at target audiences.
The success of this endeavor is clearly founded and relies upon 71 percent of adults having broadband.165 In excluded, rural regions of the country, the UK either subsidized or provided broadband to the denizens. Given the compelling reasons for using Internet-based mediums to achieve speedy and efficient dialogue with the public, the government may want to consider subsidizing technologic schemes that provide the rural population with either a phone or access to a computer. This would overcome the special barriers that hinder widespread circulation of printed press. In time-sensitive matters—for example, a government’s attempt at curtailing an epidemic—disseminating essential information could provide a return on the technological investment. In the case of public health related problems, successfully managing them can both prevent drainage of other governmental resources (healthcare) and maintain a healthy workforce.
Public Service Announcements The Department for Culture, Media and Sport has a representative committee in parliament that produced a report in April 2010. The committee turned to the Press Association in its search for proposals on public service reporting. Given that there is a growing pressure on printed press as it becomes increasingly under-resourced, the report found that newspapers were less inclined “to report on public institutions and local democracy.” Therefore, this gap in the market is used to
165
“Facts and Figures,” Office of Communications (Ofcom), November 2010. 71
both fulfill the need for regular reporting on public institutions through the placement of public announcements and support local media. Given the correlation between this financial strain and the shrinking readership, it remains an area which the government understandably intends on not investing a great deal of resources. Yet it remains useful knowledge for government to ensure that information regarding public concerns does not atomize in the printed press.
As is the case with many of the government’s schemes at information dissemination, the Internet has provided a centralized forum for public announcements of all sorts; these can be found on one site: direct.gov.uk. Some of the myriad topics covered include employment, health and wellbeing, home and community, and money, tax and benefits. Key announcements and spending reviews of each topic can be found. The page is regularly updated with notifications and content regarding emergencies and is immediately circulated through other mediums, too, such as radio and television.
Government Jurisdiction in Times of Emergency In cases of emergency, the government maintains the power to “to require suspension or restriction of a provider’s entitlement.”166 The secretary of state has reasonable grounds to interfere with broadcasting in cases where there is a threat to national security, public health, and public safety. This interference is defines as “a direction that the entitlement of the relevant provider to provide electronic communications networks or electronic communications services, or to make associated facilities available, is suspended.” The order of suspension or restriction then comes from the Office of Communications (Ofcom). Under most circumstances, this department is to take the orders of the secretary of state; however, Ofcom retains discretionary power.
If the government requires that a communications service “make associated facilities available” for its own promulgation, it is advisable to both clearly define the terms under which this is acceptable and include an independent body with discretionary power in the process of seizing control of media outlets. As there remains the obvious dangers of a government abusing
166
“Communications Act of 2003,” The National Archives, 2003. 72
such powers to its advantage—be it propagandist intentions or campaigning—having such systems in place can help ensure this does not ensue.
Public Broadcasting There are numerous public broadcasting outlets in the form of Internet, radio, and TV, while none of the main publications have any formal affiliation with the government. According to the Department for Culture, Media and Sports, there are three public service television broadcasters: the BBC, Channel 4, and S4C. The BBC is broadcast nationally and is funded primarily by the television license fee, compulsory for anyone owning a television. Channel 4 is also a nationally broadcast public corporation; however, it is self-funded through advertising. Wales—devolved from the central government—has its own equivalent of Channel 4, which is funded by both advertising and governmental grant-in-aid. While Channel 4 and S4C, however, are, in part, financed through private advertising, it is of interest to us to examine the ways in which the BBC differs from these channels.
Unlike its two other counterparts, the BBC is exclusively funded by the government, forgoing any commercial support. It has been highly successful in presenting itself as a unique example of objectivity, exempt from the pressures of the funding that many media firms find themselves under. The Office of Communications (Ofcom) is an independent body, responsible for licensing, regulating, and monitoring public service broadcasters. The BBC, furthermore, benefits from the regulatory intervention of a Royal Charter (this applies, too, to its radio and online content).
The BBC’s Royal Charter is updated every decade and is to be revisited in 2016. The purpose of it is to ensure that “the BBC shall be independent in all matters concerning the content of its output, the times and manner in which this is supplied, and in the management of its affairs.”167 The two governing bodies concerned with adhering to these guidelines are the BBC Trust and the Executive Board of the BBC. The Trust is concerned with setting the strategic direction of the organization and “exercising a general oversight of the work of the Executive Board.”
“Broadcasting: Copy of Royal Charter for the continuance of the British Broadcasting Corporation,” Department for Culture, Media and Sports, October 2006. 73
167
Essentially, the Trust serves to act in the interest of the public—in particular that of the licensefee payers. The Executive Board, on the other hand, concerns itself with operational management and adhering to the agenda created by the Trust. These were the priorities they set:
The Public Purposes of the BBC are as follows— (a) sustaining citizenship and civil society; (b) promoting education and learning; (c) stimulating creativity and cultural excellence; (d) representing the UK, its nations, regions and communities; (e) bringing the UK to the world and the world to the UK; (f) in promoting its other purposes, helping to deliver to the public the benefit of emerging communications technologies and services and, in addition, taking a leading role in the switchover to digital television.
It is essential to recognize that the two bodies are intended to function independently of one another.
Therefore, when the government intends on using the BBC for its own advertising purposes— e.g., public service announcements—it must get approval from the BBC for use of the public broadcasting services. It is precisely this level of distance between the government and its media which is desirable to avoid the dangers of having the two inextricably bound.
Conclusion The UK’s urban population is 90 percent of the total, which will be one of the most important differences to take into account when extrapolating from its advertising policy. Despite the substantial and fundamental differences between the United Kingdom and Bhutan, there is an argument to be made for using certain features of the government media policy in the UK when constructing a new policy elsewhere. As the country with the seventh largest gross domestic product, it can provide useful frameworks for those countries whose governments and economies are still being established. Perhaps most pertinent, its primary public broadcasting service, the British Broadcasting Corporation (BBC), is the largest broadcasting organization in the world.
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(According to an extensive 2004 study, there are approximately 150 million listeners to BBC World Service radio alone, which “equates to at least 50 per cent more listeners than any comparable international radio broadcaster.”168 At the time of the report, there were approximately 300 million monthly page impressions.) The UK’s extensive official media policy has been tried and tested, providing a clear outline of what has been successful for anyone wishing to adopt similar policies. By Natasha Noman [email protected]
168
“Press Releases: BBC World Service remains world’s leading international radio broadcaster,” BBC Press Office, June 21st, 2004. 75
Press Subsidies Case Studies
Press Subsidies Case Study 1: Canada
Canada Numerous funds managed by Canada’s federal culture ministry, the Department of Canadian Heritage, subsidize media production. In addition, the Canadian Radio-Television and Telecommunications Commission (CRTC) mandates programming quotas to encourage the production of news media in local communities. Moreover, the CRTC also taxes private cable companies to fund federal subsidy programs and requires private cable companies to demonstrate a quantifiable public benefit for mergers or acquisitions, some of which is redirected toward media production funds.
The Canada Magazine Fund (CMF) The Department of Canadian Heritage manages and funds this subsidy. The CMF aims to increase Canadian editorial content in magazines while strengthening the overall infrastructure of the industry. Although not chartered to support local or news content directly, because the CMF is open only to Canadian magazines, businesses, and associations, the CMF indirectly funds the production of local content and can additionally be used to subsidize the production of local news content. Four CMF programs provide funding. 1. Support for Editorial Content: Offsets production costs for Canadian magazines producing Canadian content. The funding received by each publication varies annually; it is calculated based on the proportion of a magazine’s claimed costs compared to the total application pool’s eligible expenses.169 2. Support for Arts and Literary Magazines: Functionally identical to the Support for Editorial Content, the SALM provides a special level of funding for magazines specialized in Canadian arts. 3. Support for Industry Development: The SID provides project-based grants to media associations in order to strengthen the competitiveness of the Canadian magazine
169
Support for Editorial Content: Applicant’s Guide 2009-2010. Canadian Heritage/Her Majesty the Queen in Right of Canada, 2009, 2. 76
industry. Grants are generally used to pay for business development, professional development, or training, to strengthen the distribution networks and infrastructure of associations, or to analyze industry trends. 4. Support for Business Development for Magazine Publishers: a project-based grant distributed to individual magazines to support their business development, professional development, training, or marketing projects. During the 2005–2006 fiscal year, the total budget for the CMF was 16 million CAD (15.6 million USD). This was divided as follows:170 Editorial Content $10 million (9.8 million USD) Arts and Literary Mag. $1 million (980,000 USD) Business Development $2.5 million (2.4 million USD) Industry Support $2.5 million (2.4 million USD)
The Canadian Television Fund The Canadian Television Fund (CTF) is a non-profit organization commissioned primarily to support the production and broadcast of Canadian television shows. The CTF is financed by the Department of Canadian Heritage and Broadcast Distribution Undertaking’s (BDUs—cable and direct-to-home satellite companies). The main program through which the CTF allocates funds is the Broadcaster Performance Envelope (BPE) stream. Eighteen percent of this funding stream is set aside to fund documentary productions.171 A BPE is the amount of funding a channel receives to support production. The amount of the support is determined by a complicated point system, which assesses broadcasters’ performance in relation to other channels applying for funding according to relative performance in four categories: audience success, historic access, regional production licenses, and aboveaverage licenses.172 In addition, the BPE allocated to each channel is subdivided and pegged to the production of either drama, children/youth, documentary, or arts and can only be used for the specific type of program designated.
170
Numbers and Issues: Annual Report 2005–2006, Canadian Heritage/Her Majesty the Queen in Right of Canada, 2007, 10-14. 171 Canadian Television Fund Stakeholders’s Report 2007–2008, 11. 172 Canadian Television Fund Annual Report 2008–2009, 120. 77
In 2009, the total amount of BPE financing for English-language productions was $134.7 million (131.5 million USD), while the total amount of money allocated by the CTF for all streams of subsidies in all languages was $283 million (276.4 million USD).173 This was funded by $182 million (177.7 million USD) from BDUs, as well as by a $119 million (116.2 million USD) grant from the Department of Canadian Heritage.174 The BDUs’ contribution is required by the CRTC. As a condition of their license, BDUs pay 5 percent of their gross annual broadcasting revenue to Canadian programming. At least 80 percent of these funds must go to the Canada Television Fund; this money is collected on a monthly basis by the CRTC and deposited into the fund.175
The Local Programming Improvement Fund (LPIF) Started in 2008, the CRTC’s Local Programming Improvement Fund (LPIF) subsidizes local television stations and supports the production of local programming in non-metropolitan markets. The subsidy is collected by the CRTC and distributed directly to local broadcasters. Its official objectives are: “1) To ensure that viewers in smaller Canadian markets continue to receive a diversity of local programming—particularly local news programming; 2) To improve the quality and diversity of local programming broadcast in these markets; and 3) To ensure that viewers in French-language markets are not disadvantaged by the smaller size of those markets.”176 In order to be eligible for a LPIF grant, a station must be based outside a city and broadcast a minimum of seven hours of local programming per week.177 Local programming is defined as “programming produced by local stations with local personnel or programming produced by
173 174
http://www.broadcastermagazine.com/issues/story.aspx?aid=1000090726 Canadian Television Fund Annual Report 2008-2009, 19. 175 The remaining 20 percent can be distributed directly by the BDUs to independent broadcasters or to other funds that support Canadian programming. 176 http://www.crtc.gc.ca/multites/mtwdk.exe?k=glossary-glossaire&l=60&w=42&n=1&s=5&t=2 177 http://www.cab-acr.ca/english/television/lpif/default.shtm 78
locally-based independent producers that reflects the particular needs and interests of the market’s residents.”178
Taxes collected from BDUs fund the LPIF. Therefore, the amount of money available for LPIF subsidies depends on the BDUs’ taxable earnings. In 2008 (the first year of the LPIF), the CRTC ruled that the contribution of these companied should be 1 percent, which brought the total amount of the fund to $68 million (66.4 million USD). For 2009, the BDUs’ contribution to the LPIF was temporarily raised to 1.5 percent of their gross revenue, and the CRTC has announced that the fund is projected to collect slightly over $100 million (97.7 million USD).179 The first third of the fund is distributed by the CRTC equally among all eligible local producers who apply. The remaining two-thirds is distributed based on how much local content was logged over the last three years by these stations.
Canadian Content Requirements (CanCon) and Local Content Quotas The CRTC obligates all licensed broadcasters to maintain quotas of Canadian programming, a requirement nicknamed “CanCon” (Canadian Content). Under current CanCon requirements, 60 percent of all programming between 6:00 a.m. and midnight and 50 percent of primetime programming aired between 6:00 p.m. and midnight must be Canadian. To be considered Canadian, a program must either be certified as such with the CRTC, or it can be automatically counted toward CanCon requirements if it is a news or public affairs program.180
These content requirements impact the provision of news throughout the country by creating incentives for broadcasters to air local news, which is far less costly to produce and less onerous to register than Canadian dramas or arts shows. Because news is considered by definition Canadian, news, current affairs, and talk programs have historically filled much of the CanCon requirement.
178
http://www.cab-acr.ca/english/television/lpif/default.shtm#7 These are the criteria in English-language markets. In French-language markets, the weekly quota is reduced. 179 http://www.channelcanada.com/Article3126.html 180 http://www.crtc.gc.ca/eng/info_sht/tv11.htm. 79
In 2009, as a result of the economic downturn and the desire to ensure the continuation of local programming, the CRTC imposed additional local programming quotas as a requirement for licensing. In English-language markets, the minimum local programming levels for 2009–2010 are fourteen hours per broadcast week in metropolitan markets and seven hours per broadcast week in non-metropolitan markets.181
Public Benefits Test The CRTC approves proposals for the transfer of control or ownership of BDUs. As one of its requirements for acceptable transactions, the CRTC demands that the parties involved in mergers and acquisitions demonstrate the public benefit that will stem from their deal. Although there is no set amount required for this public benefit, generally proposals should show that 10 percent of the value of the transaction will go toward the public’s benefit. This is called the “benefits test.”
Tangible benefits generally include operating expenditures, such as staff or programming improvements, capital expenditures for technical improvements, or grants made to Canadian talent or program development funds.182 These grants can and sometimes do subsidize news and media production.
Proposals are assessed on a case-by-case basis. In the majority of cases denied by the CRTC, lack of sufficient public benefits was the main cause. However, as previously stated, the 10 percent benefits level is merely a guideline. This can clearly be seen in the summary of these public benefits described in the following chart:
181 182
http://www.cab-acr.ca/english/television/lpif/default.shtm http://www.crtc.gc.ca/eng/archive/1993/pb93-68.htm 80
Public Benefits since 1985–86183 Cable TV # of transactions Value/cost of transactions 48 $842,586,000 (822,837,469 USD) Value of total benefits % value of benefits (average)184 Range of benefits By Cara Haberman [email protected] 2.4%-37.1% 7.3%-49.9% 0%-23.3% $97,926,000 (95,630,810 USD) 11.6% Television 14 $882,577,000 (861,891,160 USD) $162,412,000 (158,605,387 USD) 18.4% Radio 79 $409,823,413 (400,217,971 USD) $58.3 million (56.9 million USD) 14%
183 184
Ibid. As percent of purchase price of transaction. 81
Press Subsidies Case Study 2: Sweden
Sweden Sweden does not provide subsidies for radio or broadcast or cable television. However, Swedish newspaper subsidies have existed since the beginning of the 1970s. The Press Subsidies Council is the government agency responsible for allocating these state subsidies to publishers.185 In allocating funding, the council applies different funding regulations to high- to mediumfrequency publications (published three to seven times per week) than to low-frequency papers (one or two times per week). Swedish newspaper subsidies are primarily allocated for production or distribution efforts. Production subsidies are given to “second” newspapers, i.e., newspapers that have a competitor with a higher circulation in their place of publication. In 2007, the total newspaper production subsidy amounted to 433 million SeK (Swedish Kronor).186 Distribution subsidies are granted for cooperation in newspaper distribution on condition that at least two daily newspapers collaborate. They represent a modest infusion of capital: 10 oere (one-half of one cent) per paper distributed, or around 3 to 5 percent of total distribution costs.
While political support for scaling back or ending the subsidies seems to be minimal within Sweden, the European Commission recently told Sweden gradually to cut subsidies to big metro newspapers or face a formal state probe. This complaint was made on the grounds that aid distorts competition.187 A further inquiry into whether the subsidies operate in accordance with community law was triggered by a complaint from a Swedish media group, Bonnier, that competes with two subsidized dailies within Sweden. The complaint was filed with the European Union. Commenting on the investigation, EU Competition Commissioner Neelie Kroes said, “The commission recognises the importance of media pluralism for the cultural, democratic and public debate in member states and the importance of newspapers in this context, however,
http://www.sweden.gov.se/sb/d/3011/a/19032 http://reutersinstitute.politics.ox.ac.uk/fileadmin/documents/Publications/Press_Subsidies___Local_News_the_S wedish_Case_Final.pdf 187 http://europa.eu/rapid/pressReleasesAction.do?reference=IP/09/940
186
185
82
running a newspaper is also a commercial activity and the commission has a duty to prevent undue distortions of competition and trade resulting from public subsidies.”188
Some implied concerns about news subsidies are that they further centralize government authority and that newspapers would be less likely to criticize a government that subsidizes their expense. However, one survey of Swedish newspaper editors found just the opposite: newspaper editors were still willing to criticize “the government in the papers, even though they are supported by subsidies.”189
More commonly, arguments and debates center on the free-market implications of newspaper subsidies. However, in the case of Sweden, the market response to Swedish newspaper subsidies has been relatively positive. There has been no clear market pushback against the subsidies, in part, because Sweden has carefully framed the rationale for funding in market-friendly terms such as “competition, choice, and diversity.”190 Nevertheless, a theoretically strong general argument against the subsidies would highlight the costs of the market-inefficiencies protectionism produces: as the government is subsidizing companies that might otherwise fail, a market argument could be made that subsidies incentivize inefficiency or, at the very least, lessen the “market-appropriate” punishment for said inefficiencies.
Despite this inefficiency argument, the market-friendly framing of the Swedish government is more than just semantics. In fact, it points to four market-focused rationales to justify the funding program. First, the Swedish news subsidy model lowers barriers to entry. Normally, a newcomer paper with a business model reliant on advertising would need to rapidly acquire readership. This task is difficult. However, by providing production supports to low-coverage papers to offset this missing advertising revenue, subsidies help these potentially viable newcomer papers survive their infancy. And by increasing competition, the argument goes; this policy tends to increase aggregate content diversity and consumer choice within the Swedish newspaper industry.191
http://europa.eu/rapid/pressReleasesAction.do?reference=IP/09/940 http://www.eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailmini.jsp?_nfpb=true&_&ERICExtSe arch_SearchValue_0=EJ294688&ERICExtSearch_SearchType_0=no&accno=EJ294688 190 http://jci.sagepub.com/cgi/reprint/33/4/376 191 http://www.regeringen.se/content/1/c6/01/90/32/c6a0f7aa.pdf
189
188
83
Second, the model creates benefits associated with economies of scale. For low-coverage and newcomer papers, distribution costs are generally the greatest obstruction to market entry. This model permits these smaller papers to profit from the high-coverage newspapers’ benefits of scale. High-coverage papers also benefit because demand (and revenue) for their underutilized capacity increases.192
Third, the subsidies reduce overall costs to society as the cost of subsidizing a paper is less than the price of founding and starting a new one. None of the Swedish low-coverage newspapers that has gone out of business has been successfully revived, despite several attempts to do so. The lesson learned is an ounce of prevention is worth a pound of cure.193
Finally, by incentivizing competition, the Swedish subsidy model decreases the likelihood of local newspaper monopolies. Monopolies tend to put upward pressure on the price advertisers and consumers pay (particularly in Sweden where the consumer demand for newspapers is fairly inelastic) while simultaneously decreasing the diversity of content. Subsidies that target second papers may therefore help prevent the formation of monopolies that distort an otherwise wellfunctioning free market.
In considering the Swedish model in the context of a prospective US subsidy model, the following considerations should be kept in mind: (1) voter turnout is very high, 78 percent in the 2006 election; (2) newspaper readership is very high, reaching 75 percent of households each morning; (3) Sweden spends approximately 61 SeK per person on newspaper subsidies (no hard figures appeared available, but dividing the 2008 distribution plus production figures by the CIA Factbook’s 7/08 count of 9,059,651 people194 gives this crude figure). Because voter turnout and newspaper readership are higher in Sweden than in the US, the risk of small political interests exercising influence beyond their numbers in the subsidy debate is less of a concern in Sweden than it should be in the US. By Rob Grabow
192 193
http://www.regeringen.se/content/1/c6/01/90/32/c6a0f7aa.pdf http://www.regeringen.se/content/1/c6/01/90/32/c6a0f7aa.pdf 194 https://www.cia.gov/library/publications/the-world-factbook/geos/sw.html 84
[email protected]
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Press Subsidies Case Study 3: The United Kingdom
The United Kingdom Like the US, the UK is currently undergoing a review of its media system with the intent of finding ways to support the continued production of high quality news. This process, called Digital Britain, was inspired by a study commissioned by Oxford University’s Reuters Institute for the Study of Journalism that argued in favor of funding news production.195 Like the Future of the Media project, the Digital Britain project starts with the premise that the economic foundations of news publishers are becoming increasingly unstable. This trend is particularly true “in local and regional markets” where information is “the lifeblood of a vibrant economy” and where “strong, viable and diverse news media is also integral to democratic life.”196 The Digital Britain report notes, “Digital Britain is at the beginning of a new and possibly disruptive wave of local news, generated by communities for communities using free online media. Over the medium term this has the potential to be good for local pluralism and expression as commercial funding for traditional media diminishes.”197 However, there is a concern that the current content revolution will “demolish existing structures faster than new ones come into being.”198 Therefore, as part of the Digital Britain project, the UK is currently seeking ways to “help the more traditional media in building bridges to the future.”199 The following provides an overview of some of these initiatives, as well as the flagship of the British news media funding system, the BBC license fee. The BBC Television License System200 In Britain, consumers must pay an annual fee to access television broadcasts. The annual household cost for color and monochrome television licenses are £145.50 and £49.00,
195
“Ch. 5 Public Service Content in Digital Britain,” Digital Britain-Final Report, Department for Culture, Media and Sport, June 2009, 15. Available online at http://www.culture.gov.uk/images/publications/digitalbritainfinalreport-jun09.pdf 196 Ibid. 197 Ibid., 16. 198 Ibid., 17. 199 Ibid. 200 http://www.tvlicensing.co.uk/easy-read/why-you-need-a-tv-licence-ea25 86
respectively.201 A single fee is assigned per household, so multiple televisions in a home could be covered by a single license. This licensing law applies not just to TVs but to any medium through which an individual watches television programming. For example, even if you watch TV on your laptop or mobile phone, you are required to purchase a license.
The proceeds from these licensing fees account for approximately 75 percent of the BBC’s £4,606 billion in annual operating revenue. The BBC’s second most important revenue source is commercial income—approximately 20 percent—followed by World Service and BBC Monitoring grants. Collectively, these funding sources pay for the BBC’s television, radio, and Internet services.202 The table below shows the allocation of the licensing fees. The £11.63 is the monthly cost of the licensing fee based on the 2009 annual license cost of £139.5. To the right is the percentage of the licensing revenue allocated to each of the platforms. Allocation of License fee:203 (based on 2009 license fee of £139.5/Year) Television Radio Online Digital Switchover/Other £8.00/£11.63mo £2.10/£11.63mo £.61/£11.63mo £1.01/£11.63mo 68.7% 18% 5.2% 8.6%
Local Content Requirements for Radio Until recently, Ofcom’s “localness” guidelines stipulated that FM stations be required to broadcast ten hours of locally made programs each weekday during daytime hours and four hours over the weekend. AM stations had to provide four hours every day of the week, while stations based in the so-called “nations” (Scotland, Wales, and Northern Ireland) supplied at least six hours of programming from their home nation.204
Interestingly, in April 2010, Ofcom announced that commercial radio stations will be allowed to reduce their local programming from ten to seven hours per day as a means of cutting costs and
201 202
http://www.tvlicensing.co.uk/easy-read/why-you-need-a-tv-licence-ea25 http://www.bbc.co.uk/annualreport/exec/financial/highlights/highlights.shtml 203 http://www.bbc.co.uk/aboutthebbc/licencefee/ 204 http://www.ofcom.org.uk/media/news/2008/02/nr_20080206 87
protecting broadcasts of local news.205 This will come into effect in May along with the new Digital Economy Act. Radio stations are having trouble meeting costs due to a decline in ad revenues: therefore, in exchange for their commitment to provide local news bulletins on weekdays, Ofcom agreed to this cut in their general local programming requirements. Broadcasters will also be allowed to co-locate and share all their programming to reduce costs further. These content requirements are opposed by commercial radio broadcasters, who argue that a) there should be no local requirements at all and b) if there are local requirements, they should be reduced.206 On the other side of the debate, groups such as the Campaign for Press and Broadcasting Freedom, the National Union of Journalists and Estuary Media want higher local content quotas.
Digital Britain Independently Funded News Consortia (in pilot stage) The Digital Britain bill “a) supports growth in the creative and digital sectors, b) tackles online piracy and c) supports the availability of public service content, especially local news.”207 In terms of achieving the latter, the bill proposed the creation of Independently Funded News Consortia (IFNC), “a consortia of parties who will collaborate to provide regional and local news services.”208
The official Digital Britain bill describes IFNCs as, “A joining of interested parties who will provide a more ambitious cross-media proposition and enhanced localness compared with current commercial television regional news; but which, to maximize audience reach, will also broadcast in the regional news slots in the schedule of current Channel 3 Licensees.”209 Currently the details about how this will occur are still in the works, but in general the IFNC model is intended to relieve the burden on public service broadcasters—particularly Channel 3—by
205
Mark Sweney, “Ofcom: commercial radio can slash local programming,” Guardian.co.uk. April 15, 2010. Available online at http://www.guardian.co.uk/media/2010/apr/15/commercial-radion-ofcom-local-programming 206 http://www.ofcom.org.uk/consult/condocs/futureradio07/statement/. Commercial broadcasters had been pushing for seven hours per week, a reduction goal that they achieve this month. 207 http://www.culture.gov.uk/what_we_do/broadcasting/5631.aspx/ 208 “Digital Economy Bill. Provision of News: FACTSHEET,” Crown Copyright, November 2009. Available online at http://www.bis.gov.uk/digitaleconomybill/ 209 Ch 5, Digital Britain, 22. 88
letting Channel 3 stop news provision.210 IFNC’s will provide the replacement news broadcasts using public funds and will function over a variety of platforms. These consortia will probably be composed mainly of existing television news providers, newspaper groups, independent production companies and other newsgathering agencies, that will be allowed to enter the consortia after being approved during a competitive bid process.211
The program is being implemented in order to assure continuing levels of regional and local news production. It is seen as necessary because Ofcom recently conducted a study that projected that Channel 3, which currently broadcasts regional news, would enter into deficit by 2011 and that this “deficit will reach £38-64 million in 2012.”212 Because regional news is Channel 3’s biggest public service broadcasting charge (estimated at £68 million in 2010), the IFNC project will help keep regional news production and Channel 3 alive.
Another justification for the subsidy is that consumers have consistently shown that they value and want local and regional news but that public service broadcasters like Channel 3 cannot sustain their current levels of programming.213 Therefore, there is a need for an alternative model. IFNCs are believed to “offer enhanced options for localness” because they will be capable of extending local coverage, local news content gathering, the media platforms that carry local news, and the availability of news footage.214 It is unclear exactly how they will do this, but a report by Ofcom mentions “economies of scale” and “scope for news consortia to develop lower cost models of news provision through greater efficiencies or new working practices.”215 Although this will depend on the commercial arrangements that consortia members agree on, the report mentions sharing assets like property, studios, satellite trucks, or even staff and asset management systems.216
210
The bill initially stipulated that Ofcom gain a new function and be able to appoint providers of regional and local news directly. This aspect was amended and cut in the House of Commons Committee stage. http://www.culture.gov.uk/what_we_do/broadcasting/6549.aspx 211 Ch 5, Digital Britain, 22. 212 Local and Regional Media in the UK, Ofcom Discussion Document, 22 September 2009, 78. Available online at http://www.ofcom.org.uk/research/tv/reports/lrmuk/ 213 Channel 3 is estimated to enter into deficit by 2011 if it continues its current level of programming with its current business model. 214 http://www.ofcom.org.uk/research/tv/reports/lrmuk/Salford_local_media.pdf 215 Local and Regional Media in the UK, 98. 216 Ibid. 89
The system will be piloted in 2010 in Scotland, Wales, and Tyne Tees/Borders. These three IFNC pilots will entirely replace regional Channel 3 news programming in these “nations” and are expected to cost £40 million over two years. The pilot process will be a way to work out the remaining details of the program (which are many).
The pilots are also a way of projecting the future costs of the program. So far the official line is, “The costs of delivering news through consortia would depend on the level of news provision desired.”217 However, because Channel 3 spent £68 million on Regional News in 2010 and a projected £72 million in 2012, those figures are being used as estimates for the IFNC model.218 So far this subsidy will be entirely paid for with public funds; the UK government and Ofcom are still deciding whether IFNCs will be permitted advertising or other revenue opportunities as supplementary income.219 Funding decisions should be settled following the pilot stage, but at least one Ofcom report concluded that “external funding is required.”220 The report also noted that using the license fee surplus from the BBC is the government’s preferred option of supplementary funding221 and that, alternatively, “levies have been suggested,” but there is “stakeholder resistance.”222 By Rob Grabow and Cara Haberman [email protected], [email protected]
217 218
Ibid., 90. Ibid., 78. 219 Ch 5, Digital Britain, 22 220 http://www.ofcom.org.uk/research/tv/reports/lrmuk/Salford_local_media.pdf 221 http://www.guardian.co.uk/technology/2009/jun/16/digital-britain-bbc-licence-fee 222 http://www.ofcom.org.uk/research/tv/reports/lrmuk/Salford_local_media.pdf 90
A Case for Non-public Advertising Subsidies in Bhutan
Introduction Approximately 70 percent of media revenue in Bhutan comes from public advertising.223 This financial dependency puts the government and the domestic media in a precarious position. On the one hand, the government, in accordance with its constitutional mandate to do so and its fidelity to the Gross National Happiness pillar of good governance, wants to promote free and independent media. On the other hand the press is financially dependent on the government it is expected to hold accountable, which may compromise its independence.
While the conflict of interest is apparent, Bhutan gives no hint that it intends to use public advertising to censor or influence media content to base ends. In fact, the opposite appears to be true; the ministry of information wants to incentivize the media to support GNH values, rewarding this behavior with targeted public advertising placements. This is a laudable target, but one which could undermine the press’s independence and duly compromise Bhutan’s fourth pillar of good governance.
Recent histories of numerous countries, provinces, and municipalities from around the world show that when public advertising is conditionally tied to content—“good” or “bad”— particularly in environments in which the media are heavily reliant on public advertising for viability, abuse and corruption can become inveterate. The structures that mandate socially “good” content generally also permit the “bad.”224
Guy Berger the proprietor of Grocotts Mail, a South African paper, knows these risks well. In 2007, he saw his paper’s well of advertising dry up because the Grahamstown municipality “disapproved of the paper’s coverage.”225 While Berger eventually won his appeal, after throwing “constitution and other legal arguments,”226 at his would-be censors, his example is
223 224
Kinley Dorji Email http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 225 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 226 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 91
illustrative of the dangers of public advertising—that it often ends up being used as both a carrot to reward coverage that supports the government and as a stick punish media that do not.
“While the media are not entitled to receive any advertising at all, what they are entitled to is not to be descriminated against,” says Berger.227 More blunt in his language, Robert Bousquet, senior advisor with Canada’s Communication Policy says, “Governments should not use advertising to subsidize the press,” a sentiment echoed by Darian Pavli, an attorney with the Justice Initiative at the Open Society during an interview on November 3, 2010.228, 229
Instead of being used as a subsidy tool, public advertising’s circumscribed role in Bhutan should be to “inform the public in an open, fair, and cost-effective way about important government policies, programs, and services (and how to benefit from them),” in essence allowing the governement to communicate with citizens and citizens to communicate and give feedback to the government while remaining “responsive to the diverse information needs of the public.”230
Per the media’s inability to be extant without public succor, this decision is only part of a solution. Despite Bhutan’s commendable willingness to lend financial assistance, to eschew glaring conflicts of interest, and to ensure that media are and appear to be independent, the government should consider a subsidy policy specifically intended to aid the media as an alternative to one that uses public advertising to do so. Thoroughly vetted policies in Sweden, Canada, and the United Kingdom provide alternatives for newspaper production and distribution subsidies, radio and television support for local content, and sundry grants for culturally important programming, which can be distributed in a equitable manner with sufficient devolution of authority, oversight, and well-thought-out guidelines to diminish risks of abuse.
Some implied concerns about news subsidies are that they further centralize government authority and that media would be less likely to criticize a government that subsidizes their expense. However, if carefully structured, that propensity can be dramatically diminished, as one
227 228
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf Interview with Robert Bousquet, Rob Grabow. 11/2/2010. 229 Interview with Darian Pavli, Rob Grabow and Barbara Magid. 11/3/2010. 230 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 92
survey of Swedish newspaper editors found: newspaper editors were still willing to criticize “the government in the papers, even though they are supported by subsidies.”231
If recent history is considered, the risks of a subsidy model that use public advertising (as opposed to a more specialized policy) to steer monies or influence content seem to be particularly prone to abuse. While “the specifics of how soft censorship is applied vary from region to region and even from country to country within a region,” soft-censorship through government advertising is uncomfortably common in several parts of the world, including: Eastern Europe and South and East Asia, and is especially problematic in Latin American and Africa.232
Misuse of Government Advertising
Argentina A report published in 2008 by the Argentine Association for Civil Rights and the Open Society Justice Initiative found that the “national government regularly abuses its advertising powers, including through excessive allocations to political favorites and denial of advertising in retaliation for critical coverage. Such abuses are even more marked at the local level, where media are, as a rule, more dependent on provincial and municipal advertising.”233 This last point is particularly pertinent to Bhutan where roughly 70 percent of the media budget currently comes from government advertising.234 A recent Supreme Court ruling declared such actions unconstitutional, stating in its ruling, “Government discrimination in the placement of advertising is an act of indirect coercion that is contrary to freedom of speech,” later adding, “The Government may not manipulate advertising by giving it to or taking it away from media outlets on the basis of discriminatory criteria.”
http://www.eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailmini.jsp?_nfpb=true&_&ERICExtSe arch_SearchValue_0=EJ294688&ERICExtSearch_SearchType_0=no&accno=EJ294688 232 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 233 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 234 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 93
231
Despite the ruling, identifying soft censorship is problematic. This is why Catalina Botero, special rapporteur for freedom of expression for the Organization of American States, said it was her view that government advertising is inappropriate as a subsidy, adding that, in deciding who receives funds for public advertising, “the determining criterion should be reaching the audience that it is supposed to reach.”235
Colombia In rural regions of Colombia, where media are almost completely reliant on public advertising to stay in business, “the government splits up its advertising budgets among radio journalists without regard to their stations’ audience reach.” In return, not surprisingly, “the radio stations then treat the government with deference.”236 The consequence as Jaime Abello, the executive director of the Foundation for New Iberian-American Journalism, pointed out was that “The importance of the message was secondary to rewarding reporters who would provide favorable coverage.” 237 Mexico Mexico’s story is similar in that “the withdrawal of government advertising on the local and national levels has become a common tactic for discouraging criticism of the government.”238 In one instance, the governor of Puebla, Mario Marin Torres, denied public contracts to three online papers, which had been “critical of his administration and reported on his alleged connection with a businessman implicated in a pedophile ring.”239 The backlash from the editors at one of the papers, e-consulta, which had been denied advertising, was severe. “It’s absurdly unfair; they provide contracts to media outlets that have no ratings and that cannot provide valid circulation numbers, yet they cut us off because we are critical,” Rodolfo Ruiz Rodríguez, the paper’s director told CEPET.240
235 236
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 237 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 238 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 239 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 240 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 94
Bermuda One of the risks when public advertising is used as subsidy is that it becomes difficult to determine whether or not advertising is being withdrawn for a legitimate reason or simply because a medium is critical of the government. Often it’s the latter speciously cloaked in the former. Such appears to be the case in Bermuda. “In March 2008, the government of Bermuda cut its advertising budget of about $800,000 for the Royal Gazette.”241 The government, which didn’t “explain why it believed electronic media would be more effective in reaching the people,” cited a strategic shift away from print in favor of online advertising in reaching this decision. Government advertising, however, continues in the island’s other privately owned newspaper despite its lower circulation.”242 Alarmed by this action and doubtful of the government’s rationale, editors at the Royal Gazette cried foul, arguing that the cuts were in retaliation to the paper’s campaign that “supported access to public information legislation in Bermuda.”243 Reporters Without Borders, the Inter-American Press Association, the World Association of Newspapers, and the International Press Institute all expressed concerns in letters to Bermuda’s premier.244
Pakistan In 2006, the Pakistani government withdrew advertising “in the Dawn Group, one of Pakistan’s leading English-language media companies, after Dawn refused a government request for a news blackout of military action.”245
Nepal Following a declared state of emergency, Nepal’s Information minister confirmed a monarchical decree to “stop payment for advertising to private media.”246 Information Minister Tanka Dhakal added to this directive, saying the government was “seriously thinking of giving incentives to those media working for the nation and the crown, so we have stopped giving ads to the private media temporarily.” The government then started to steer advertising to media outlets deemed
241 242
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 243 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 244 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 245 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 246 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 95
“responsible.” Nepal’s case underscores the risk of tying eligibility for government advertising to compliance with state directives, even noble ones such as GNH.
Botswana The Media Institute of Southern Africa sees a “growing tendency to use the placement of advertising as inducement to influence editorial decisions,” adding, “Freedom of expression cannot be held at ransom to economic factors; otherwise, the right to information, as enshrined in various international and regional conventions and protocols, would have no meaning.” 247
Moldova In Moldova, a report by the Independent Journalism Center found that “the print-run does not seem to be a criterion that public agencies take into account when they decide to post advertising in newspapers.”248 Related, that same study found that “advertising paid for from public funds is the most visible form of funding of the media by the state and is an important economic level used to influence them.”249 That sort of indirect censoring underscores the risks Bhutan faces in using public advertising funds to subsidize the media.
Conclusion Bhutan, which wants to promote GNH and build a knowledge-based society, needs to subsidize the press and must advertise things like tenders, health advisories, and large campaigns. In using public advertising to conditionally (or unconditionally) subsidize the press, a seemingly praiseworthy marriage of interests—between Bhutan’s broad goal of promoting GNH values and a more circumscribed objective of subsidizing the press through government advertising—may sound a death knell to the credibility of the country’s press. Bhutan also risks the appearance of not fully respecting its fourth pillar of good governance and may appear to be anti-freedom of speech.250
247 248
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 249 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf
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Because of the media’s reliance on public advertising to stay operational, if public advertising is used as a subsidy, and more disconcertingly as a subsidy for GNH-promoting content, in addition to the risks of abuse such a policy would invite, it creates a more simple collision of interests. What if the newspaper that has the ability to reach the audience at risk for a small pox outbreak is deemed by the government not to promote GNH values? Would the government be barred from advertising in that paper? Irrespective of the answer, the conflict becomes messy. There is an important place for GNH in public advertising, e.g., the government running a GNHpromotional campaign—it just should not be used to manacle or direct the content of a free press. Roberto Sabo, executive director of the Association for Civil Rights in Argentina summed up this idea well with an example: “If a state government advertises to attract tourists, it should not subsidize local media with that advertising; rather it should place those ads in media whose audiences are located elsewhere.” 251 By Rob Grabow [email protected]
For More Information
A large body of literature exists on the subject of public advertising. The following section highlights some key references identified throughout the team’s research:
Public Advertising Policies
• Australia’s Current Advertising Guidelines: “Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies” http://www.finance.gov.au/advertising/docs/Guidelines-on-Information-and-AdvertisingCampaigns-by-Australian-Government-Departments-and-Agencies-March-2010.pdf
251
www.fopea.org/content/download/1301/.../Soft%20censorship%20report.pdf, 7. 97
•
Canada’s Current Advertising Guidelines: http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text
•
“Engaging Through Social Media,” Central Office of Information (COI), November 2010.
•
Industrial Promotion Policies—Central Government Advertisement Policy (with effect from 1 June 2006) http://advertising.indiabizclub.com/info/government_policies
Misuses of Public Advertising
• Canada’s Sponsorship Scandal http://www.cbc.ca/news/background/groupaction/ • CIMA’s Censorship Report http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf • Rafael Di Tella. “Government Advertising and Media Coverage of Corruption Scandals,” Ignacio Franceschelli, NBER Working Paper. October 2009. http://www.nber.org/papers/w15402.pdf • India’s Advertising Bloopers o Priscilla Jebaraj. “African Jumbo in Incredible India Ad,” http://www.thehindu.com/news/national/article799389.ece o Press Trust of India, “3 Crores in 2 Months for Rajiv Gandhi Ads,” NDTV, Friday January 29, 2010, New Delhi. • Sally Young. “Not Biting the Hand that Feeds: Theories for understanding government advertising in Australia” • Sally Young. “Political advertising: hey big spender!” in M. Simms and J. Warhurst, editors, Mortgage Nation: The 2004 Federal Election, Perth: API Network. 2005. • Sally Young. “Reform and Resistance: The Regulation of Government Advertising in Australia.” Australasian Political Studies Association Annual Conference. 25-27 September 2006, University of Newcastle, City Hall, Newcastle. • Sally Young. “The Regulation of Government Advertising in Australia: The Politicisation of a Public Policy Issue.” Australian Journal of Public Affairs. 2007.
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South Africa Abuses http://www.journalism.co.za/index.php?option=com_content&Itemid=100009&catid=16 5&id=1067&view=article http://nml.ru.ac.za/blog/guy-berger/2008/10/24/resources-about-government-advertisingboycotts-private-media.html
Annual Reports
• Australia’s 2009–10 Campaign Advertising Annual Report “Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009–10” • Canada’s 2008–2009 Public Advertising Annual Report http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-20082009-eng.pdf • India’s 2009–2010 Annual Report for the Directorate of Advertising and Visual Publicity http://www.davp.nic.in/aenglish0910.pdf • South Africa’s Budget http://www.treasury.gov.za/documents/national%20budget/2008/ene/6%20gcis.pdf
Evaluations of Policy
• Allan Hawke. “Independent Review of Government Advertising Arrangements,” February 26, 2010. http://www.finance.gov.au/advertising/docs/Independent-Review-of-GovernmentAdvertising-Arrangements.pdf • “Facts and Figures,” Office of Communications (Ofcom), November 2010.
Tenders
• Tenders http://www.gcis.gov.za/aboutus/procurement/index.html
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Alternative Media Subsidy Programs • Canada’s Local Programming Improvement Fund
http://www.crtc.gc.ca/multites/mtwdk.exe?k=glossaryglossaire&l=60&w=42&n=1&s=5&t=2 • Canadian Program Certification http://www.crtc.gc.ca/eng/info_sht/tv11.htm • Canada’s Public Benefit’s Test http://www.crtc.gc.ca/eng/archive/1993/pb93-68.htm • “Efficient Servants of Pluralism or Marginalized Media Policy Tools: The Case of Swedish Press Subsidies” http://jci.sagepub.com/content/33/4/376.full.pdf+html • “How Were the United Kingdom’s License Fees Spent in 2009–10” http://www.bbc.co.uk/aboutthebbc/licencefee/ • “Newspaper Subsidies in Sweden Pose No Dangers, Its Editors Feel.” http://www.eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailmini.jsp?_nf pb=true&_&ERICExtSearch_SearchValue_0=EJ294688&ERICExtSearch_SearchType_ 0=no&accno=EJ294688 • “Press Subsidies and Local News: The Swedish Case.” http://reutersinstitute.politics.ox.ac.uk/fileadmin/documents/Publications/Press_Subsidies _Local_News_the_Swedish_Case_Final.pdf • United Kingdom’s Television Licensing Requirements http://www.tvlicensing.co.uk/easy-read/why-you-need-a-tv-licence-ea25
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doc_155711042.pdf
Advertising or advertizing is a form of communication for marketing and used to encourage, persuade, or manipulate an audience (viewers, readers or listeners; sometimes a specific group) to continue or take some new action.
Government Advertising Policies:
Some Findings from Around the World
Robert Grabow Sankalpa Dashrath Barbara Magid Michelle Moghtader Natasha Noman
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Faculty Advisor: Anya Schiffrin
Acronyms ACPD AdMIS AIR ANC AOR ASA BBC BDUs BPE CanCon CMF COI CPDC CRTC CSA CTF DA DAVP DFP GAGIA GCIS HoC ICC IFNC IMC LPIF MDDA Advertising Co-ordination and Partnership Directorate Advertising Management Information System All India Radio African National Congress (South African ruling political party) Agency of Record Advertising Standards Authority of South Africa British Broadcasting Corporation Broadcast Distribution Undertakings Broadcaster Performance Envelope Canadian content requirements Canada Magazine Fund Central Office of Information Communications Procurement Directorate Canadian Radio-Television and Telecommunications Commission Communication Service Agency Canadian Television Fund Democratic Alliance (South African political party and official opposition to the ANC) Directorate of Advertising and Visual Publicity Directorate of Field Publicity Guidelines for Australian Government Information Activities Government Communication and Information System Head of Communication Independent Communications Committee Independently Funded News Consortia International Marketing Council of South Africa Local Programming Improvement Fund Media Development and Diversity Agency
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MERX MIB MPCC NESB OGC PCO PIB PPP PWGSC RFP RGoB SABC
Canada’s Electronic Tender Service Ministry of Information and Broadcasting Multipurpose Communication Centers Non-English Speaking Background Office of Government Commerce Privy Council Office Press Information Bureau Purchasing Power Parity Public Works and Government Services Canada Request for Proposal Document Royal Government of Bhutan South African Broadcasting Corporation
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Table of Contents
Foreword............................................................................................................................................................................................... 5 Executive Summary ......................................................................................................................................................................... 7 Introduction.......................................................................................................................................................................................10 Public Advertising Case Studies ..............................................................................................................................................14 Public Advertising Case Study 1: Australia ..................................................................................................................15 Public Advertising Case Study 2: Canada ......................................................................................................................29 Public Advertising Case Study 3: India ...........................................................................................................................39 Public Advertising Case Study 4: South Africa ...........................................................................................................52 Public Advertising Case Study 5: United Kingdom...................................................................................................68 Press Subsidies Case Studies ....................................................................................................................................................76 Press Subsidies Case Study 1: Canada ............................................................................................................................76 Press Subsidies Case Study 2: Sweden ...........................................................................................................................82 Press Subsidies Case Study 3: The United Kingdom ...............................................................................................86 A Case for Non-public Advertising Subsidies in Bhutan .............................................................................................91 For More Information...................................................................................................................................................................97 Public Advertising Policies ...................................................................................................................................................97 Misuses of Public Advertising .............................................................................................................................................98 Annual Reports ...........................................................................................................................................................................99 Evaluations of Policy ................................................................................................................................................................99 Tenders ...........................................................................................................................................................................................99 Alternative Media Subsidy Programs........................................................................................................................... 100
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Foreword Professor Anya Schiffrin, School of International and Public Affairs The government of Bhutan is in a historic moment regarding its policies on the media. As the country grows, so will the number of media outlets and their reach. Investment in the media sector will likely expand and also the range of options available to the public. Technology will play an important role in giving readers more choices as to how they get information and what sort of information they choose to receive. Foreign investors will want to step up their involvement in the Bhutanese media scene. Bhutan is in a unique position. Because it is now setting government policy, it can learn from the experiences of other countries around the world and decide which, if any, are compatible with the government’s own goal of promoting Gross National Happiness. Certainly there are pitfalls to be aware of. In many cases, excessive involvement by government has led to media that are beholden and serve as little more than a mouthpiece that does propaganda for government policies. Another category of failures is the use of media by political parties that engage in divisive and distorting reporting aimed at fomenting opposition that undermines meaningful democratic processes. Excessive involvement by corporate owners can lead to capture by special interests and media that promote the political ambitions and financial interests of the owner(s). The rush for profit and circulation can lead to a lowering of standards and coverage that promotes sensationalism and superficiality. None of these scenarios serves the public well. Worse, the prevalence of one often becomes an excuse for the other. For example, governments sometimes use the sensationalism of the media or their factual mistakes as excuses to meddle with editorial independence. There are no easy solutions. Rather, media policies must be viewed as a work in progress, which will likely need adjusting over time. I am honored to present the fine work of my students. The project was born out of a ten-day visit we made to Bhutan last May, which happily coincided with World Press Freedom Day. My offer of research support to the Secretary of the Ministry of Information and Communications was kindly accepted, and I accordingly recruited graduate students at Columbia University with a particular interest in
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media policy and economic development. The team of five has spent many hours collecting data, interviewing policy makers and scholars, and closely examining the experiences of other countries around the world in order to bring to bear information that would be relevant to Bhutan. While we drew on the help of many people in the researching of this report, any factual errors are, of course, our own responsibility. We were privileged to serve the government and people of Bhutan with our work and hope our humble contribution will be of use as you continue your discussion of this important subject. We wish you the very best with your deliberations. Sincerely, Anya Schiffrin Director, International Media, Advocacy and Communications specialization School of International and Public Affairs Columbia University, New York [email protected] Tel: +1 212 854 7188
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Executive Summary
Recognizing the importance of a robust and vibrant media, governments around the world have grappled with the question of how best to support its development. Today, Bhutan is in a similar situation. The policies that are implemented now will set the course for the future and will inevitably have long-term effects that are difficult to predict. It’s impossible to plan for every eventuality, but what can be done is to try to set up a framework that will promote good practices and allow for speedy repair and remediation in the case of difficulties. Part of this framework must be a system of media support that is transparent, has appropriate checks and balances and which promotes arms-length decision making. Respect for the editorial independence of the media should be paramount in all planning.
Using government advertising to subsidize the media is one option that the government of Bhutan is considering, and the Minister of Information of Bhutan has drafted guidelines governing public advertising policy. However, a formal policy has not yet been implemented, and so, in order to augment the Ministry of Information’s extensive research on the subject, the Minister of Information asked a team of graduate students from Columbia University to prepare a report to help inform Bhutan’s on the use of government funds in advertising.
Accordingly, we spent three months researching media advertising policies around the world in order to augment the Ministry of Information research about what has and has not worked in the past. Much of the research and scholarship on this important subject has been done in Australia (previously an example of what not to do), in Canada and in Latin America where the Open Society Justice Initiative has worked to formulate recommendations. Although there is not a vast body of research from which to draw on, there is certainly enough for us to find some “lessons learned” that may be relevant to Bhutan. Our mandate was to look at what sorts of advertising support the Bhutanese government could provide to the local media. However, we found that this question was so closely tied to larger questions of media independence/development that we inevitably strayed into broader policy questions about media support.
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Some of the key findings from our three-month study include:
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There is a wealth of policy options available to governments that wish to promote/develop the media.
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These include direct subsidies, collection of licensing fees, public programming funds, and grants to support local, cultural, “socially beneficial,” and public affairs content.
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Using government advertising to support the media is an extremely risky business, and experts in this area repeatedly warned us against it. They pointed to the potential for corruption and government censorship and cited examples in Argentina, Australia, and South Africa as pitfalls to avoid.
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Using government advertising to support the media is not the same as having the government pay for messaging and campaigning in the media. Examples of this would be government campaigns to promote vaccines for children or tourism campaigns and tenders. This category of advertising is well respected around the world, and countries such as Canada have done an excellent job at laying out frameworks for this kind of arms-length advertising policy. Through these campaigns, Bhutan could promote GNHvalues without the risk of influencing the editorial independence of domestic media.
Below is a summary of some relevant government policies from Australia, Canada, India, South Africa, and the United Kingdom:
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Australia’s current policy was adopted in 2006 in response to nearly a decade of abuse under the Howard administration, during which public advertising was corruptly used to promote a partisan agenda (see Public Advertising Case Study 1). Not surprisingly, the focus of policy recommendations is to depoliticize public advertising, prevent conflicts of interest, and devolve power in such a way that no one person or cabal can easily exploit public advertising for individual or political gain.
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Canada’s well-thought-out government advertising policy, regarded as one of the world’s most transparent, separates small, mundane forms of public advertising known as public announcements (tenders, health advisories, job openings, and office hours) from larger
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initiatives that can include cultural, heritage, and tourism promotion (see Public Advertising Case Study 2). Canada also has strict conflict of interest guidelines, which promote transparency, accountability, and a separation of authority to discourage abuse of public advertising funds for individual financial or political gain. Canada is a useful example for Bhutan in thinking about best practices in public advertising.
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India’s government advertising is based on the premise that in a democracy the government has to ensure that its policies and programs are properly presented and correctly interpreted through the press and other media to the people on whose support and goodwill it holds office1 (Public Advertising Case Study 3).
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South Africa’s transformation into a democratic post-apartheid state in 1994 not only required the unification of a country which had been divided along racial lines for fortysix years (Public Advertising Case Study 4), but also provided an opportunity to improve communication between the government and rural and underserved populations. Awarding government grants to media outlets that promote diversity and facilitate communication with underserved populations has been a success, while South Africa’s attempts to subsidize the press through advertisements failed because of government corruption.
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The United Kingdom has a carefully crafted online tendering system that that helps users search for and understand opportunities (Public Advertising Case Study 5). This system, which documents all open tenders on a central Website, encourages transparency and accountability and provides better “value for money.” The UK also blends thoughtful subsidy programs and funds used to support the media with a demarcated relationship between the government and media in order to preserve public trust.
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Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India. 9
Introduction
Governments around the world pay for advertising in their local media. Some post tender announcements in local newspapers. Others provide health messages, environmental warnings, or safety advisories. Some do employment advertisements, post office hours, or give instructions for obtaining passports. Others promote large campaigns worth hundreds of thousands or millions of dollars. Government advertising can be big business.
Canada’s federal government for example spent 79.5 million Canadian dollars (77.6 million USD) or $2.38 (2.32 USD) for every Canadian in 2009 on public advertising. Of this, $74 million (72.27 million USD) went to large campaigns to educate the public about tax savings accounts, financial reforms in the wake of the contemporaneous economic crisis, and military recruitment initiatives. The balance paid for public announcements, including tender notices representing over $14 billion (13.67 billion USD) in contracts. Most distributions of public funds are made based on merit, but even in Canada’s carefully designed system, abuse is possible. In one instance, “$100 million [97.7 million USD] was paid to a variety of communications agencies in the form of fees and commissions” that were “basically designed to generate commissions for these companies rather than to produce any benefit for Canadians,”2
While the boundary lines can blur, we need to distinguish between advertising that is part of government messaging and daily business and which is common all over the world and advertising that is politically motivated and aimed at handing out subsidies to favored media. This latter form of advertising is now commonly frowned upon in the academic and media development community.
The problem is that, even with the best of intentions, governments giving advertisements intended to support local media often find their policies are corrupted and transformed into subsidies that succor the supporters of those in power. Recent histories of many countries suggest that when public advertising disbursements are conditionally tied to content—even if
2 http://www.cbc.ca/news/background/groupaction/ 10
that content is positively regarded—particularly in environments in which the media are heavily reliant on public advertising for viability, abuse and corruption become common. The lure of personal or political gain is simply too enticing to ignore, and the structures that mandate socially “good” content generally also permit the “bad.” 3
A 2009 report by the Center for International Media Assistance, part of the National Endowment for Democracy, a US government agency based in Washington, DC, notes that Soft, or indirect, censorship can be defined as the practice of influencing news coverage by applying financial pressure on media companies that are deemed critical of a government or its policies and rewarding media outlets and individual journalists who are seen as friendly to the government. Examples of this practice abound in countries in every part of the world.4 Studies in Latin America are often cited as examples of a government policy that has turned bad. In a 2008 report, The Price of Silence, published by the Open Society Institute’s Justice Initiative and the Buenos Aires-based Association for Civil Rights, researchers warned that In most of the [seven] countries studied, we found pervasive abuse by government officials who manipulate distribution of advertising for political and personal purposes—in clear violation of international and regional free expression norms. The effects of such abuses are especially insidious when public sector advertising is critical to the financial survival of media outlets, which is particularly true for local media.5
As examples from around the world suggest, connecting media support to government policies often undermine media independence. We hope that our case studies from around the world provide some useful background information The question of how to subsidize the media in Bhutan is certainly a crucial part of any government media policy.
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf. http://cima.ned.org/publications/research-reports/soft-censorship-how-governments-around-globe-use-moneymanipulate-medi 5 The report, which includes guidelines for advertising policy can be found here: http://www.soros.org/initiatives/justice/focus/foi/articles_publications/publications/silence_20080811
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Public Advertising Case Studies
The old adage holds that we study history to learn from past mistakes and to avoid replicating them in the future. Today, as Bhutan develops its policy, the country is perfectly placed to acquire information from the public advertising histories of other countries. As Bhutan creates its government advertising policy, it may be helpful to learn from mistakes of other actors in this arena or to examine some best practices from across the globe. The team chose five countries to examine in greater depth: Australia, Canada, India, South Africa, and the United Kingdom. These countries were all chosen for closer analysis because they may be able to aid Bhutan in developing its guidelines—either towards certain practices that have proven successful or away from what have emerged as policy failures. Although the lessons from these five countries must be condignly contextualized, the information below may prove useful for Bhutan.
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Public Advertising Case Study 1: Australia
Executive Summary Australia’s government advertising policy was implemented in 2006 in response to nearly a decade of abuse under the Howard administration during which public advertising was used to promote a partisan agenda.
Australia: From Abuse to Reform In Australia between 1996 and 2005, the Howard government spent more than AU$1 billion (971.5 million USD) on advertising that was widely considered to be partisan.6 There are clear, documented cases of spikes in government advertising spending prior to elections.7 In 2004 alone, just months before the election, Howard’s government spent upwards of AU$30 million (29.2 million USD) on advertising the accomplishments of the government.8 Howard’s advertising was no secret; many in the opposition and in the general public understandably viewed these timely advertising campaigns as a strategy to garner support for the incumbency in the lead-up to the elections. Calls for change and increased regulations came from auditor general reports, Parliamentary inquiries, and Private Members’ Bills.9 But change was slow in coming. Although against the spirit of public advertising, the government’s actions were not considered strictly illegal according to the guidelines regulating government advertising at the time.10 During the government’s decade-long abuse of advertising, the guidelines at the time—the Guidelines for Australian Government Information Activities (GAGIA)—were neither robust enough nor specific enough to prevent the misuse of funds. In fact, the GAGIA contained no clauses protecting advertising from being used to promote a government’s political agenda.11 The authors of the GAGIA addressed how a government should spend money but did not have
6 Sally Young, “Reform and Resistance: The Regulation of Government Advertising in Australia,” (refereed paper presented to the Australian Political Studies Association Conference, University of Newcastle, September 25-27). 7 Sally Young, “Not Biting the Hand that Feeds: Theories for understanding government advertising in Australia,” Democratic Audit of Australia—August 2005, 2. 8 Sally Young, “Political advertising: hey big spender!” in Mortgage Nation:The 2004 federal election, ed. M. Simms and J. Warhurst (Perth: API Network). 9 Young, “Reform and Resistance.” 10 Young, “Theories for understanding government advertising in Australia,” 2. 11 Young, “Theories for understanding government advertising in Australia,” 2.
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the foresight to adequately address how the government should not spend money. In the absence of strict regulations to curb abuse, institutional mechanisms were also lacking.
However, change did come, and in July 2008, the Rudd government released the “Guidelines.” These guidelines were strict on what a government would not be permitted to use advertising funds for. On July 2, 2008, Lindsay Tanner MP and Senator John Faulkner wrote a press release that explained that: “these new procedures [the Guidelines] will now give the public confidence that campaigns are legitimately authorised, properly targeted and non-political . . . This [new] guideline ensures that a Government cannot advertise, as ‘government policy’, a proposed election policy, as the Howard Government did in its tax advertising campaign in 1998.”12
To prevent further abuses and ensure appropriate policies, Allan Hawke was appointed to conduct an independent review of the Guidelines, which was released publicly in March 2010.13 Shortly thereafter, the amended and most recent version of the Guidelines was released.
Years of Abuse: Why Was the Status Quo Maintained? To understand why the government’s guidelines were inadequate during Howard’s reign, it is important to understand a little about the history of government advertising in Australia. Before the 1990s, there was no reason for skepticism regarding government advertising. In the 1970s, the government began using advertising campaigns, which usually received bipartisan support, to inform the public of basic health messages and social wellbeing.14 In the 1970s, a gentlemen’s agreement dictated the rules of the game: taxpayer money would not be used to advance a particular party’s political agenda.15 Because of this governmental self-restraint, protections against the use of government advertising money for partisan purposes were not adequately codified in government advertising laws.
It was only in the late 1980s and the 1990s that the Australian governments began to stray from
John Faulkner and Lindsay Tanner, “Joint Media Release: New Advertising Guidelines,” Minister for Finance and Deregulation, July 2, 2008. 13 “Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009–10,” Financial Management Group, Australian Government Department of Finance and Deregulation, Financial Management Group, October 2010. 14 Young, “Reform and Resistance.” 15 Young, “Reform and Resistance.” 16
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these unwritten agreements, and for the first time public monies were used to advance a partisan goal.16 But the guidelines were not amended until 2008, a couple of decades after the emergence of this abusive behavior. How is it possible that Australian advertising guidelines were not amended until 2008? Why did clauses ensuring that public funds would not be used for political advertising not appear beforehand?
The political, economic, and media climate of Australia is generally considered to be “advanced” or “developed.” Yet despite continued and conspicuous use of government advertising to push a partisan agenda, reform moved very slowly. The answer, not surprisingly, lies in politics and economics. Conflicts of interest among many actors slowed change. Because a number of powerful or influential entities benefited from the previous advertising arrangement, disincentives for change were strong. Both the incumbency, which benefited politically, and the media, which benefited economically, had few reasons to reform the system.
Politically, change stalled for many reasons. While Howard’s opposition was vocal in its criticism of the government’s use of advertising for its own agenda, the incumbency benefited from the status quo. Sally Young, a leading Australian scholar on government advertising policy, refers to the political climate of Australia at the time as “cold,” meaning that “government, obtaining a ruling party benefit from an existing system, has demonstrated long-term resistance to any reforms despite attempts by other, usually influential, policy actors to achieve change.”17 Politically, in this “cold” climate, change stalled because the incumbency resisted policy modifications.
But why did the media, traditional whistleblowers, not play this particular role and alert the public to these corrupt practices? Economics. In this advertising climate, government funded the very sources that could have exposed this form of injustice. Media sources that received government advertising revenue were less likely to report on the government’s advertising abuses, however partisan, for justifiable fear that the government would pull its ads.
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Young, “Reform and Resistance.” Young, “Reform and Resistance.” 17
Sally Young goes through a comprehensive analysis of media and supports this rational economic theory with data: While commercial television news has only infrequently reported the issue of government advertising (Young 2006b), newspapers (which profit far less from government advertising) have regularly called for change. For example, newspapers have used bluntly worded editorials to express their concerns over the federal government’s advertising with headlines such as: - ‘The costs of self-promotion’, the Sydney Morning Herald, 29 June 2004. - ‘Playing politics advertorially’, the Canberra Times, 1 July 2004. - ‘Government advertising over the top’, the Courier Mail, 1 July 2004 - An advertising rort’, the Australian, 31 August 2005.18 As Sally Young herself points out, this logic falls perfectly into Herman and Chomsky’s framework of propaganda theory.19,20 Because the government is unlikely to place advertisements in press critical of its policies, economic logic stipulates that those who remain quiet will be those who continue to receive government subsidies in the form of paid advertisements. “TV and radio stations are particularly vulnerable to this filter because broadcasters obtain about 100 per cent of their revenue from advertising (while newspapers derive less, about 75 per cent).”21 Not surprisingly, Howard’s government employed television advertising most heavily.22
The Good News (and Some Warnings) Although it is too early to say definitively, Australia seems to be a success story. From a history of abuse and partisan government advertising, have emerged robust, new guidelines, institutions to enforce them, and a stronger system of checks and balances.
Australia’s example poses questions for Bhutan. How can the country prevent an “Australia”? How can it ensure that there are laws and enforcement systems that are able to prevent use of
Young, “Reform and Resistance.” Edward S. Herman and Noam Chomsky, “A propaganda model” in Manufacturing Consent (Pantheon Books, 1988). 20 Young, “Theories for understanding government advertising in Australia,” 7. 21 Young, “Theories for understanding government advertising in Australia,” 7. 22 Young, “Political advertising.”
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government funds for a partisan political agenda? How can it make sure that the government is not subsidizing media for reasons of political self-interest rather than ideals of GNH or the greater good? Bhutan must create a policy that is robust enough to prevent partisan abuse but flexible enough to accommodate changing contexts and the emergence of new technologies.
Australia’s System: The Good, the Bad, and Implications for Bhutan The following section analyzes the specifics of Australia’s government advertising policy, with a close look at the pros and cons of the specific guidelines where appropriate. These findings are applicable to many countries, although a country’s context will determine the exact adaptation. All of these, after adaptation to the local context, can inform Bhutan’s advertising policy.
Advertising Rationale Australian government campaign advertising expenditures for the financial year 2009–2010 were reported at 114.7 million Australian dollars.23 Such a large budget line must be closely
monitored and have a well-thought-out rationale.
In the case of Australia, advertising serves two general purposes: “at one level, government advertising has an important democratic function. The public has a right to be informed about the programs that their taxes fund. Equally, governments have a right to establish a framework for delivering this information, subject to parliamentary scrutiny.”24
The guidelines explain that: 8. The underlying principles governing the use of public funds for all government information and advertising campaigns are that: a. members of the public have equal rights to access comprehensive information about government policies, programs and services which affect their entitlements, rights and obligations; b. governments may legitimately use public funds to explain government
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“Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009–10.” “Research Note: Information, Analysis and Advice for the Parliament,” Parliamentary Library Department of Parliamentary Services, June 21, 2004, No. 62. 19
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;25 Democratic governments must justify their spending to the public and must also be able to communicate information to promote wellbeing through information campaigns.
Types of Advertisements The types of advertisements used by the government are in keeping with the two general purposes of the government’s advertising rationale. Public monies and taxpayer dollars go towards non-campaign advertising in Australia, which includes, but is not limited to:
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recruitment for specific job vacancies; auction and tender notices; invitations to make submissions or apply for grants; notification of date- and/or location-specific information (for example, notification of a public meeting at a particular time and place); and other public notices.26
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The Big Five There are five principles by which all government advertising campaigns must abide. Collectively, they clarify the purpose of the campaigns, requiring relevance, coherence with the end goal, objectivity, efficiency, and legality:
Principle 1: Campaigns should be relevant to government responsibilities. Principle 2: Campaign materials should be presented in an objective, Fair, and accessible manner and be designed to meet the objectives of the campaign. Principle 3: Campaign materials should be objective and not directed at promoting party political interests. Principle 4: Campaigns should be justified and undertaken in an efficient, effective,
“Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies,” Commonwealth of Australia, Department of Finance and Deregulation, March 2010. 26 “Guidelines on Information and Advertising Campaigns.” 20
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and relevant manner. Principle 5: Campaigns must comply with legal requirements and procurement policies and procedures.27
Principle 3 is crucial, given Australia’s history; above all, Australia’s government advertising guidelines were amended so that they would not be used for partisan agendas or for the promotion of a particular policy, as has happened in the past.
Clear Definitions Australia’s Guidelines include clear definitions throughout, leaving no room for ambiguity. A campaign, for example, is defined as the following: “For the purposes of these Guidelines, an advertising campaign involves paid media placement and is designed to inform, educate, motivate or change behaviour.”28 Clearly outlined definitions promote clarity. However, governments must be wary of making the definitions too narrow to apply to evolving contexts.
Localized Advertising In Australia, there are provisions for local advertising and “both Commonwealth and State governments are entitled to taxpayer money to provide the public with information about their programs.”29 This decentralized campaign allows for local governments and authorities to address the local, state-specific needs of the population through more targeted, relevant, or appropriate campaigns. Because the governments of different states have different issues to communicate to the public, targeting a specific audience may also be more cost-effective. However, it also leaves room for great diversity of messaging from government bodies, and potential disparities in information coverage. Australia is a very large, developed country with high quality infrastructure. It is important to take geography and infrastructure into consideration when planning how localized advertising should be addressed.
Targeting Disadvantaged Groups According to Australia’s guidelines, “special attention should be paid to communicating with
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“Guidelines on Information and Advertising Campaigns,” 10. “Guidelines on Information and Advertising Campaigns,” 9. 29 “Research Note.” 21
any disadvantaged individuals or groups identified as being within the target audience. Particular attention should be paid to the communication needs of young people, the rural community and those for whom English is not a convenient language in which to receive information.”30 Likewise, “imagery used in campaign materials should reflect the diverse range of Australians. There should be recognition of the full participation of women, Indigenous and culturally and linguistically diverse communities by realistically portraying their interests, lifestyles and contributions to Australian society.”31
Although Australia is predominantly English-speaking, Australia makes an effort to reach those who are linguistic minorities. For example, in the government’s advertising budget, “specialist consultants and translation costs” appear under two budget lines: Non-English Speaking Background (NESB) Communications and Indigenous Communications.32 In countries with linguistic diversity, language-specific local advertising provisions will ensure that messaging is delivered in a manner that is comprehensible and familiar to as many people as possible. Theoretically, one could argue that advertising in multiple languages would detract from cultural unity, however getting important messages out to linguistic minorities, particularly concerning public health and safety, will benefit society at large.
Advertising Platforms The government of Australia disseminates advertising through “print, radio, digital, cinema, television or out-of-home media.”33 Different types of media allow the government’s advertising broad reach—people from different socioeconomic and cultural backgrounds may access information preferentially through only one medium. Broadening advertising channels can allow diversification of recipients. In the case of countries with illiterate populations or with infrastructural challenges, newspaper and digital advertising may not be appropriate, for example. Depending upon the income level and electric grid of a country, TV or radio may be an appropriate means through which to advertise. Cell phones, which have recently become
30 31
“Guidelines on Information and Advertising Campaigns.” “Guidelines on Information and Advertising Campaigns.” 32 “Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009-10,” 15. 33 “Guidelines on Information and Advertising Campaigns,” 11. 22
available to many at low cost, even those on the so-called bottom of the pyramid, are another means of reaching disadvantaged, remote, or impoverished populations.
Cost should also be considered in choosing an advertising medium. Since governments, particularly poorer governments, are operating in conditions of limited resources, it is important that advertising and messaging be as economically efficient and cost-effective as possible. For example, in Australia, “the cost of government advertising is minimized by the targeted use of media other than television advertising.”34 In fact, the guidelines stipulate that “the medium and volume of the advertising activities should be cost effective and justifiable within the budget allocated to the campaign.”35 In Australia and much of the developed world, digital advertising has minimized costs while maximizing reach. However, this may be neither practical nor effective in other countries with differing digital landscapes. The independent review recognized the tension between reach and cost-effectiveness in some cases, stating that “in practice, there can be a conflict between the objective to achieve savings and the Government’s duty of care to ensure all members of the public have equal access to comprehensive information.”36 It is important to target all members of society, not simply the ones who are conveniently and cheaply accessible.
It is also crucial to have a system of monitoring and evaluation in place. It is important to evaluate the outcomes/impact of advertising schemes, to ensure broad coverage, cost-efficiency, and effectiveness. The guidelines stipulate that: “campaign materials should be tested with target audiences to indicate they are engaging and perform well against the objectives of the campaign.”37 Pre-testing is also recommended so that necessary changes can be made to a campaign before it goes public.
Accountability Government advertising guidelines alone will not prevent taxpayer money from funding partisan advertising. An adequate, uncorrupted enforcement system is also necessary.
34 35
Allan Hawke, “Independent Review of Government Advertising Arrangements,” February 26, 2010. “Guidelines on Information and Advertising Campaigns.” 36 Hawke, “Independent Review of Government Advertising Arrangements,” 20. 37 “Guidelines on Information and Advertising Campaigns,” 10. 23
The framework for government advertising campaign scrutiny has changed over the course of the past few years. The most recent iteration dates from March 2010. New accountability and reporting procedures were put into place, and the Independent Communications Committee (ICC) was established: The ICC provides a report to agency Chief Executives on whether campaigns comply with Principles 1 to 4 of the Guidelines. It is ultimately the responsibility of the Chief Executive to consider whether a campaign fully complies with the Guidelines (including compliance with legal requirements and procurement policies) and to ask the relevant Minister to launch the campaign or approve its launch. The ICC’s advice to Chief Executives is published on the Finance website as soon as possible after the launch of relevant campaigns. Chief Executives must also publish their certification of compliance with the Guidelines on their agency website when the campaign launches.38 It is hoped that this system will now be robust enough to prevent further abuse. The new policy incorporates checks and balances to make sure that no party has a conflict of interest that could lead to misuse of government advertising. It is important to separate the campaign designers and conceivers from the approvers and funders.
While this is important, it may also be helpful to have a centralized agency to coordinate government advertising. The Independent Review explains that:
“coordination by a central agency is necessary and appropriate to: (a) ensure whole-of-government perspectives are brought to bear; (b) avoid duplication, competition in the advertising market and conflicting messages; (c) compensate for varying levels of capability in departments; (d) raise issues at an early stage; and (e) coordinate contract management and procurement.”39
Financial reporting and accountability are crucial; in an attempt to promote accountability and
38 39
“Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009-10,” 9. Hawke, “Independent Review of Government Advertising Arrangements,” 21. 24
transparency, a full report and detailed budget must be produced for Parliament biannually.40 Australia’s past shows the need for accountability and transparency to ensure that a particular partisan agenda is not unjustly promoted. For this reason and following just that, the system of checks and balances in Australia was restructured in 2008 and further tweaked in 2010. Checks and balances are crucial in all governments, although that accountability must not come at the cost of all else. A system with too many checks and balances may become clumsy, bureaucratic, and slow, something to keep in mind when creating a policy and enforcement mechanisms.
Campaign Threshold For this reason, a campaign threshold was implemented; campaigns over AU$250,000 (242,875 USD) are scrutinized by the auditor general: “the Independent Communications Committee considers campaigns and provides advice to Chief Executives on all advertising campaigns valued at more than AU$250,000 (242,875 USD) or where requested to do so by the Chief Executive.”41 Although this figure would need to be amended for different countries, it serves to cut down considerably on bureaucracy and push smaller, cheaper campaigns more quickly through bureaucratic roadblocks. It is possible that this efficiency comes at a price: it is much harder to prevent against corruption or misappropriation of funds, however small the scale, with this type of threshold.
Bureaucracy In the Independent Review of Government Advertising Arrangements, Hawke stressed the need for: “communications flexibility, to adopt new technologies, and to adjust elements of a campaign while it is underway. It would be desirable for the Guidelines and associated arrangements to be more adaptable to emerging trends.”42 Because of past abuses, the government advertising policy was understandably wary of allowing for changes in midcampaign advertising, as these are difficult to monitor. Although restrictions on mid-campaign changes can be an important piece of accountability assurance, it may also hinder a campaign’s efficacy. Perhaps the pendulum has swung too far in the other direction.
40 41
“Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009-10,” 9. “Guidelines on Information and Advertising Campaigns,” 6. 42 Hawke, “Independent Review of Government Advertising Arrangements,” 21. 25
In fact, the agencies touched on a number of these shortcomings in the 2008 Guidelines in their feedback. Specifically, Feedback from agencies indicates that the current approval processes: (a) result in delays in delivering advertising campaigns by required timeframes; (b) impose significant cost burdens on agencies; (c) involve a very high administrative burden, particularly in fulfilling the AuditorGeneral’s requirements; (d) have resulted in missed advertising opportunities and a limited ability to adopt new media technologies; and (e) re-certifications of variations to campaigns do not allow campaigns to be adjusted after commencement to reflect feedback or changed circumstances, and have hampered agencies’ abilities to respond to cost-effective media opportunities that arise at short notice.43 Exceptional Circumstances Australia’s policy is subject to suspension in the case of extreme necessity, though it must formally report to the Parliament: “the Cabinet Secretary can exempt a campaign from compliance with these Guidelines on the basis of a national emergency, extreme urgency or other compelling reason. Where an exemption is approved, the Independent Communications Committee will be informed of the exemption, and the decision will be formally recorded and reported to the Parliament.”44 This clause is both crucial and worrisome. It is important that governments be able to communicate with the public during an emergency without going through cumbersome advertising approval procedures. However, allowing suspension comes with risks. To prevent abuse, there must be political mechanisms that place checks on when an emergency can be called, and by whom. It is crucial that strong institutions prevent a political actor from declaring a state of emergency as a simple abuse of power. Although this goes beyond the purview of the advertising guidelines, strong political mechanisms and strong institutions form the foundation of a strong government advertising policy. Government advertising does not
43 44
Hawke, “Independent Review of Government Advertising Arrangements.” “Guidelines on Information and Advertising Campaigns,” 5. 26
exist in a vacuum. It is both affected by and supportive of a larger political system.
Feedback and Independent Review As previously mentioned, Australia’s government sponsored an independent review of government advertising policy, and then requested internal departmental feedback. This process allowed a disinterested, external reviewer to evaluate Australia’s policy and provide unbiased feedback. Allowing for departmental input also ensured that those on the inside, with intimate knowledge of the policy’s practice and implementation, had more ownership of the process. If non-repressive, free institutions are in place and external evaluators have nothing to fear from providing honest criticism, this process of periodic, independent review can be beneficial in keeping the system modern, accountable, and efficient. But if an independent evaluator is not free to provide criticism, this review will become an exercise in diplomacy or inutility. The risk of constant review, feedback, and change, of course, is that a system would become too reactionary or tighten too much. Government policies should not be regularly rewritten but should be supple enough to adapt to changing contexts.
Comparison between Australia and Bhutan There are clear historical, demographic, and geographic differences between Australia and Bhutan, and analyzing Australia’s government advertising policy in order to inform Bhutan’s may not seem like a natural choice at first glance. One could put forth a handful of arguments highlighting the similarities between the Commonwealth and Bhutan. Both countries try to strike a balance between environmental protection and economic development, for example. Both are working towards a “holistic” model of development. But frankly, at least as much distinguishes them as unites them.
Australia is a developed regional superpower—Bhutan a small, relatively isolated developing country. Australia, rich in natural resources, is endowed with a 25,760 km coastline.45 Bhutan, on the other hand, is a small, landlocked country. The CIA’s World Factbook estimated Australia’s population of 21,262,641 to be ethnically homogeneous, with 92 percent whites, 7 percent
“The World Factbook: Australia,” CIA, accessed October 20, 2010, https://www.cia.gov/library/publications/theworld-factbook/geos/as.html. 27
45
Asians, and 1 percent Aboriginals and others.46 On the other hand, with a population of just under 700,000, Bhutan’s ethnic groups are more evenly weighted with Bhote comprising 50 percent of the population, Nepalese 35 percent, and indigenous or migrant tribes 15 percent.47 Literacy is high in Australia, and 99 percent of the population, both males and females, is estimated to be literate. In Bhutan, 47 percent of the population but only 34 percent of females was estimated to be literate as of 2003.48 Linguistically, the countries are distinct as well—a reflection of the ethnic make-up of the populations. According to Mr. Joseph Lo Bianco, Chief Executive of the National Languages and Literacy Institute of Australia, “English has no de jure status but it is so entrenched as the common language that it is de facto the official language as well as the national language.”49 Bhutan has much more linguistic diversity: Dzongkha is the official language, but various Tibetan and Nepalese dialects are also widely spoken.
The countries’ economic landscapes are also very different. Australia boasts a competitive and thriving market economy. Gross Domestic Product (GDP), adjusted for Purchasing Power Parity (PPP) was estimated to be 851.1 billion USD in 2009, or 18th in the world.50 GDP per capita was estimated at $40,000 USD or 19th in the world.51 In stark contrast, Bhutan ranks 170th for global GDP (PPP adjusted), and in 2009 GDP per capita was estimated to be $4,700 USD.52 It is important to note the limitations of GDP as an indicator, however. GDP has been widely criticized as Western-biased and inadequate when it comes to measuring “what matters.” Bhutan has led the world in the development of its own holistic system of evaluating “progress” or “development”—Gross National Happiness. GNH seeks to go beyond GDP in defining wellbeing through the four pillars of sustainable development, cultural values, natural environment, and good governance. GNH, the abovementioned factors, and many others, must
“The World Factbook: Australia.” “The World Factbook: Bhutan,” CIA, accessed October 20, 2010, https://www.cia.gov/library/publications/theworld-factbook/geos/bt.html. 48 “The World Factbook: Bhutan. 49 Joseph Lo “Pluralist Nations: Pluralist Language Policies?” (at the 1995 Global Cultural Diversity Conference Proceedings, Sydney). 50 “The World Factbook: Australia.” 51 “The World Factbook: Australia.” 52 “The World Factbook: Bhutan.”
47
46
28
be considered when applying Australia’s lessons to the Bhutanese context. Although more than geography separates Australia and Bhutan, lessons from Australia’s experience can be applied to any country developing or reforming its government advertising policy, including Bhutan. Australia was selected for analysis not because of its similarity to Bhutan but because the history of Australia’s government advertising policy serves as a warning to all countries regardless of geography, politics, or culture. Australia’s current policy is shaped by experience, and the lessons learned are universally applicable and widely scalable. Following downright abuse by the Australian government, which used public advertising to forward its own interests, Australia reformed its policy. While a historical analysis of Australia’s government advertising policy is useful in informing governments what not to do, the country’s robust guidelines today paint a picture of massive policy shifts and positive reform and can provide insight into what to do. To be viable, the recommendations contained within this paper must be tailored to the Bhutanese context. But the main lesson from Australia’s experience—the importance of protecting government advertising from being used to further partisan political agendas—is of universal importance. By Barbara Magid [email protected]
Public Advertising Case Study 2: Canada
Executive Summary Canada’s well-thought-out advertising policy separates small, mundane forms of public advertising, known as public announcements (tenders, health advisories, job openings, and office hours), from larger initiatives that can include cultural, heritage, and tourism promotion. The country also has strict conflict-of-interest guidelines, which promote transparency,
accountability, and a separation of authority to discourage abuse of public advertising funds for individual financial or political gain, which may be of interest to Bhutan.
Purpose of Government Advertising in Canada
29
The stated purpose of government advertising in Canada is to “ensure that communications across the Government of Canada are well co-ordinated, effectively managed and responsive to the diverse information needs of the public.”53 More specifically, government advertising aims to inform the public in an open, fair, and cost-effective way about government policies, programs, and services (and how to benefit from them), allowing the government to communicate with citizens and citizens to communicate and give feedback to the government. For example, public advertising provides people instructions on “where to click, call or visit, so that the public can take action on matters that are important to them in an easy, convenient, and timely manner.”54
The Decision to Advertise In Canada the decision to advertise begins with the individual institution—usually the communication head of the department—which may do so and purchase advertising space or time in any medium to inform Canadians “about their rights or responsibilities about government policies, programs, services, or initiatives,” or about tenders or “risks to public health, safety, or the environment.”
Types of Advertising Canada cleaves advertising into two camps: promotion of government priorities, also known as initiatives, and public notices, commonly referred to as public announcements. Approximately $74 million (72.3 million USD)of Canada’s $79.5 million (77.6 million USD) 2008 federal public advertising budget was used to promote government priorities, predominately in large campaigns.
Large Campaigns Among the many examples were the following: The Consumer Product Safety Campaign to increase awareness among Canadians about potential hazards associated with products purchased outside Canada, Celebrate Canada’s Culture Initiative to recruit professional artists to represent Team Canada in an international cultural competitions in Lebanon, and Advantage Canada, to
53 54
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drum up awareness about the government’s economic action plan to reawaken the depressed economy.
Public Notices Canada used the remaining $5 million (4.8 million USD) in its budget for public notices, such as tenders (which, subject to competitive bidding, awarded $14 billion—13.67 billion USD—in contracts in 2006), health advisories, and public meetings or hearings, as well as more mundane advisories like government business hours, federal employment opportunities, and information about how to get a passport.
Language of Advertising Canadian law mandates that all public advertising be available in English and French, further stipulating that government institutions ensure that “positive measures” are taken to implement Canada’s commitment to “enhance the vitality of official language minority communities and address the needs, concerns and languages preferences of such communities.”55
Political Neutrality of Public Advertising Public advertising is legally bound to be apolitical: “Institutions must not use public funds to purchase advertising in support of a political party.”56 Even with good laws in place, of course, the means of misusing political funds, particularly during campaign season exists. In a hypothetical scenario, for example by offering information about great work done by the current government, the ruling party could imply that it deserves credit for the advertised successes. To mitigate the risk of this and other types of political-focused abuses, all government institutions must “suspend their advertising during general elections,” except when “an institution is required by statute or regulation to issue a public notice for legal purposes,” which includes health advisories, safety or environmental concerns, or employment or staffing notices.57
Learning from the Past: Separating Authority
55 56
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 57 http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 31
Following a 2004 scandal in which Canada’s federal auditor found that “$100 million [97.7 million USD] was paid to a variety of communications agencies in the form of fees and commissions” that were “basically designed to generate commissions for these companies rather than to produce any benefit for Canadians,”58 the government amended its already careful policy and structure to provide great accountability and transparency and arguably needed bureaucracy through a more rigorous separation of entity responsibilities, divided as those (1) requesting funds, (2) approving funds, (3) releasing funds, (4) overseeing funds, (5) producing ad campaigns and buying ad space, and (6) measuring the effectiveness of the campaign.
Structuring an Advertising Policy The process works thus. Once a public institution decides to advertise, there are five key actors involved: (1) the institution requesting funding; (2) Public Works and Government Services Canada (PWGSC), which has three important, relevant organizations, (a) the Agency of Record, (b) the Advertising Co-ordination and Partnership Directorate (ACPD), and (c) the Communications Procurement Directorate (CPD); (3) the Privy Council Office (PCO); (4) the Treasury; and (5) the Cabinet. Six basic stages are involved in the development and execution of an advertising initiative: (1) planning and approval, (2) contracting for advertising services, (3) advertising production, (4) pretesting (only for large campaigns), (5) media placement, and (6) a post campaign evaluation and report.59
1. Planning and Approval. A public institution looking to advertise works with the Privy Council Office (PCO) to develop an advertising proposal that includes objectives, target audiences, measurable outcomes, and strategy. Once complete, PWGSC reviews the proposal for legal compliance before passing it on to the Cabinet, which approves proposals (under the umbrella Government Advertising Plan), twice annually. Following Cabinet approval, institutions submit the proposal to the Treasury for funding.60
2. Contracting for Advertising Services. Once funding is approved, institutions contact the ACPD and CPD within the PWGSC to initiate the contract and implementation process, submit a
58 59
http://www.cbc.ca/news/background/groupaction/ http://www.tbs-sct.gc.ca/pubs_pol/sipubs/comm/cpgcp-ppcgc03-eng.asp#_Toc137523379 60 http://www.tbs-sct.gc.ca/pubs_pol/sipubs/comm/cpgcp-ppcgc03-eng.asp#_Toc137523379 32
“scope of work,” and then receive a project registration number from the ACPD. The CPD, with input from the ACPD and the institutions to find suppliers, issues an advertising contract, and then the CPD is charged with managing the contract and ensuring proper administration and documentation.61
3. Advertising Production. Institutions work with their selected contractors to develop the advertising strategy, design, and create final advertising materials for print, broadcast, or electronic media. Along the way, institutions must advise the ACPD and CPD of any changes in the original scope of work or media buy strategy.62
4. Pretesting. This applies only to large campaigns exceeding $400,000 (390,625 USD) in media buy, which then require benchmarking and focus grouping.63
5. Media Placement. Institutions develop a media-buy plan with their advertising services contractors, review and approve them internally, then submit them to their PCO strategic analysis for review. Once reviewed, the institution submits the plan to ACPD for a buy authorization. Once authorized, the Agency of Record—a private contracting entity within the PWGSC selected through a competitive bidding process—purchases the media space. The Agency of Record, however, cannot purchase media for an institution unless a work authorization and project work number have been assigned.64
6. Post Campaign Evaluation and Report. This applies only to large campaigns exceeding $100,000 (97,656 USD) in media buy. In addition to monitoring Website hits and page views after a campaign, the Canadian Government monitors calls to 1-800-CANADA, the country’s toll-free hotline for information about any important government initiatives or public announcements, where citizens can also voice concerns and complaints and have them
61 62
Ibid Ibid 63 Ibid 64 http://www.tbs-sct.gc.ca/pubs_pol/sipubs/comm/cpgcp-ppcgc03-eng.asp#_Toc137523379 33
addressed. All calls are coded and associated with the appropriate public advertising initiative and campaign.65
This model, while admittedly bureaucratic, helps ensure sufficient oversight and separation of authority to hedge the risk of potential abuses. The sophistication and accountability of the model also provide political cover for persons interested in increasing the public advertising budget, even in this case, in the wake of a recent public advertising scandal. Four years after the shakedown, the Harper administration “more than doubled the government’s ad budget, increasing it from $41.3 million (40.3 million USD) to $86.9 million (84.9 million USD).”66 And despite questions in the Montreal Gazette, such as, “Did this increase involve advertising with a partisan sub-text? Were there legitimate reasons for the spend to spiral?” the plan moved forward. 67
Selecting an Advertising Platform The Government of Canada thus advertises in all forms of media. With each campaign, in deciding which platform to use, the institution looking to advertise (or its supervising agency) considers the weight of the objectives, audience demographics, research about the target audience, media availability, reach, costs, and two-language and minority-language considerations. Excluding public notice buys, which institutions can purchase directly without approval from the Agency of Record, the table below, which shows a modest decrease in aggregate and per capita spending on public advertising, breaks down government advertising amounts by platform in 2008–2009 and provides totals for 2006–2009. Since 2006, government advertising has marginally and steadily decreased in aggregate and per capita figures.68
Fig 1: The 2008–2009 platform breakdown of aggregate and per capita government advertising in millions of $, except per capita figures which are in standard $.69 Platform Type Expenditure (’08–’09) Expenditure (’08–’09) % of Total (’08–
65 66
http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf http://www.suite101.com/content/government-advertising-policies-a63439 67 http://www.suite101.com/content/government-advertising-policies-a63439 68 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 69 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 34
Millions of Canadian Millions of US Dollars Dollars Weekly/Community $6.15 Papers TV $20.71 Radio Magazines Cinemas Out of Home Internet National Dailies Total ’08–’09 Total ’07–’08 Total ’06–’07 $8.67 $1.67 $1.54 $6.49 $8.91 $11.79 6 USD 20.22 USD 8.47 USD 1.63 USD 1.50 USD 6.34 USD 8.70 USD 11.51 USD
’09)
9.33 31.41 13.15 2.53 2.34 9.84 13.52 17.88
$79.5 ($2.38 per capita) 77.6 USD (2.32 per capita) $84.1 ($2.55 per capita) 82.1 USD (2.49 per capita) $86.9 ($2.66 per capita) 84.9 USD (2.60 per capita)
Targeting Audiences Outside of Canada While institutions may place or purchase advertising directed at audiences outside of Canada to promote Canadian interests, before doing so they must consult with Foreign Affairs and International Trade Canada to ensure compatibility with government communications and marketing abroad.70
Domestic-owned Media Considerations There are no provisions that mandate that public funds can be used only to buy space in Canadian-owned media—that is governed by law. However, recent laws changed the requirement that the firms providing advertising services be 100 percent Canadian-owned to at least 80 percent Canadian-owned.71
Withdrawing Public Advertising Beyond the ability to cancel media purchases two months prior to national elections, or in the event of violation of the government’s public advertising guidelines, specific circumstances
70 71
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 35
under which the government may withdraw advertising are elusive. It appears that the Agency of Record, which is closely monitored by the PWGSC, has the ability to withdraw funding in accordance with law and public advertising guidelines. While the ACPD may withhold issuance of or cancel a project registration number, which would effectively end a campaign, the central consideration—and where the bulk of the risk resides—seems to be in the selection of the company used to produce the advertising and separately the media buys, both of which are selected through competitive bids.72
Efficiency in Advertising While concerns about the inefficiency of governments have merit, Canada, which emphasizes cost effectiveness as part of its strategy, appears to do more than pay lip service to market-based incentives. First, while not explicitly stated, the competitive bids for advertising apply the market-based thinking that increased competition, in this case for public advertising projects, tends to put downward pressure on prices and upward pressure on quality of service and thereby positive pressure on efficiency and cost-effectiveness for the Canadian taxpayer. Second, the government, with oversight from the PWGSC, also selects the Agency of Record to handle its media buys through a “selective” and “competitive” bidding process that, by centralizing buying authority for all government institutions, tends to ensure the government is able to negotiate volume discounts on bids, which becomes necessary given their scope: one of the most important functions of public advertising involves announcements of tenders for sundry government works projects; in 2006, these tenders, which catalyze the competitive bidding process for government projects, led to $14 billion (13.67 billion USD) in contract awards.73 Finally, by creating a public advertising policy that is transparent, the Government of Canada strengthens consumer confidence and diffuses important information that the public needs in order to make informed decisions about finances, health, and the environment.
Public Advertising Institutions of Note The Canadian system has related significant elements of note. First, it has an Advertising Management Information System (AdMIS) that, managed by PWGSC, enables departments to
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access public advertising information and also fully tracks Government of Canada advertising activities, including project information and expenditures, throughout the life cycle of each initiative.74 Second, Canada has an electronic tendering service called MERX, used by the government to post searchable procurement notices and bid-solicitation documents for access by suppliers and contract officers.75 Third, Canada has a formal government request for proposal document (RFP), posted on MERX, through which advertising services suppliers are invited to submit proposals for government projects.76 Fourth, Canada mandates advertising branding, meaning that institutions must use the “Canada wordmark” when identifying their participation in a collaborative arrangement to enable public recognition of the contributions of the Government of Canada.77 Fifth, Canada has a “one-stop service delivery network,” called Service Canada, that “offers citizens quick access to all Government of Canada programs” through 1-800-O-Canada, on the Web, and through physical points of service.78 Sixth, Canada’s Library and Archives Act requires all institutions to deposit all newly published materials in various formats with the library and archives of Canada, the permanent repository of the government and its institutions.79 Seventh, PWGSC offers trainings for all employees with staff, academics, industry experts, and media associations in aspects ranging from the full fundamentals of government advertising to more advanced concepts, such as campaign analytics, with the implied objective of ensuring government advertising is current and effective.80
Conclusion Geographically, Canada is over 212 times as large as Bhutan, its population, though small at 33,311,40081 is almost 50 times Bhutan’s, and it has a literacy rate of 99 percent, over twice as high. Canada is also historically secular, has an inveterate parliamentary system, a welldeveloped infrastructure, per-capita GDP 8 times greater than Bhutan’s, and approaches government advertising through a lens influenced by Western politics, values, and culture.82 So,
74 75
http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 76 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 77 http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 78 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 79 http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text 80 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 81 http://www.google.com/publicdata?ds=wbwdi&met=sp_pop_totl&idim=country:CAN&dl=en&hl=en&q=population+of+canada 82 https://www.cia.gov/library/publications/the-world-factbook/geos/ca.html 37
while useful in an abstract analysis of public advertising policy, clearly Canada’s policy is imperfect and somewhat elaborate for a smaller nation like Bhutan. Policy recommendations must therefore lend themselves to adaptation for existing entities to adjust to new responsibilities, and as with any significant policy initiative, implementation must incorporate certain cultural and pragmatic considerations to minimize potential resistance and mitigate or at least phase in the growing pains to existing practices. That said, however, the critical principles of separation of political and economic interests that removes the political benefit of misappropriating government advertising monies, its two national languages (French and English), which can inform Bhutan’s desire to offer advertisements in two languages (English and Dzongkha), as well as a reviewable openness of information remain at the core of any attempt to ensure a principled independence and integrity in Bhutan. 83,84 By Rob Grabow [email protected]
83 84
Sally Young Interview, Barbara Magid. http://www.google.com/publicdata?ds=wbwdi&met=sp_pop_totl&idim=country:CAN&dl=en&hl=en&q=population+of+canada 38
Public Advertising Case Study 3: India
Executive Summary The rationale behind government advertisement in India functions upon the premise that in a democracy, the government has to ensure that its policies and programs are properly presented and correctly interpreted through the press and other media to the people on whose support and goodwill it holds office.85
Introduction to India’s Advertising Policy Government advertisements in India are not meant to be a source of financial assistance to any publication or media outlet. To this end, no advertisements are issued as a matter of routine but only when the need or occasion arises.86
A total number of 11,551 government advertisements were released to various newspapers throughout India during the financial year 2009–10. The government spent 244,13,000 rupees (approx. 536,000 USD) on these advertisements. This was supplemented by advertisements on radio, television, and other forms of publicity like door-to-door campaigns, outdoor boardings, and exhibitions. Expenditure on audio-visual publicity was Rs. 170,00,000 (approx. 373,093 USD). This included approximately 95,06,914 outdoor displays and 80,000 copies of printed material, like speeches of the prime minister, calendars, and other government publicity literature.87
The process of government advertising in India is a complex one with multiple checks and balances at every stage; from the decision of creating an advertisement to the actual placement of the ad and measuring its impact.
The relationship between the Indian government and the media agencies, especially newspapers, is equally complex. Newspapers in India are not subsidized by the government. Government advertisements are not a source of income for newspapers. Instead, the government agencies,
85 86
Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India http://info.pondicherry.gov.in/addraft-1.pdf 87 http://www.davp.nic.in/aenglish0910.pdf 39
such as the Directorate of Advertising and Visual Publicity (DAVP), get advertising rates from these newspapers that are up to 40 percent cheaper than the commercial rates for advertising in the papers. In addition to this discount on advertising rates, the DAVP also gets a 15 percent agency commission from the newspapers.88
Given the lack of subsidies on newsprint as well as the advertising rates that the DAVP commands, the various newspapers associations in India between 2004-2008 rallied to get more concessions from the government. After appointing an independent commission that liaised with Indian Newspapers Society, Indian Federation of Small and Medium Newspapers, Association of Indian Magazines, the Association of Small Newspapers of India, Federation of Small Newspapers, and Indian Language Newspapers Association, the following two changes to the current policy were made:
A stimulus package for print media companies comprising a waiver of the 15 percent agency commission on DAVP advertisements and a 10 percent increase in DAVP rates to be paid as a special relief on loss of revenue in non-governmental advertisements was made. It was also stated that the “pulling power” of the newspaper is an important criterion in evolving a suitable rate for advertisement. While emphasizing pulling power as a relevant factor in determining DAVP advertisement rates, newspapers should also appreciate the fact that government advertisement is a separate category. Apart from having a certain amount of news value, they provide useful information to the reader. Appearance of government recruitment advertisements, for example, in a newspaper add to its pull and prestige and attract a greater readership. A balanced view has, thus, to be taken on this aspect.
It was recommended that the DAVP advertisement rate should consider the following components: • • •
88
Newsprint cost Processing charges Reasonable profit
http://www.davp.nic.in/final_report.pdf 40
• • •
Weightage for small and medium newspapers Pulling power weightage for higher circulation Commission for display advertisements
Even after incorporating the recommendations made, rates for government advertising still remain significantly lower than the commercial rates that the newspapers charge.
Structure India’s advertising policy is set and controlled by the Ministry of Information and Broadcasting (MIB).89 The primary mandate of the MIB is to ensure that all Indian citizens have access to a free flow of information via various media, like radio, TV, the press, publications, advertising and Internet.
The MIB is responsible for setting up a policy framework that allows a healthy development of various mass media in the country and formulating the policy for dissemination of information.90 Its main functions are:
• • • • • • •
News services through All India Radio (AIR) and Doordarshan (DD) for the people Development of broadcasting and television Import and export of films Development and promotion of the film industry Organization of film festivals and cultural exchanges Advertisement and visual publicity on behalf of the Government of India Handling of press relations to present the policies of the Government of India and to get feedback on the government policies
• •
Administration of the Press and Registration of Books Act, 1867 in respect of newspapers Dissemination of information about India within and outside the country through publications on matters of national importance
“Ministry of Information and Broadcasting, Government of India,” last updated on January 2010 http://india.gov.in/outerwin.php?id=http://mib.gov.in/ 90 Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India. 41
89
•
Research, reference, and training to assist the media units of the ministry to meet their responsibilities
•
Use of interpersonal communication and traditional folk art forms for information/ publicity campaigns on public interest issues
•
International cooperation in the field of information and mass media
Based on these functions, the MIB is further subdivided into independent divisions. Government advertising and public service messages are largely under the purview of two main departments—the Directorate of Advertising and Visual Publicity and the Directorate of Field Publicity. Other departments, like All India Radio, Doordarshan, the Publications Department, and Press Information Bureau, also handle some specialized aspects of government advertising.
Directorate of Advertising and Visual Publicity Function. The Directorate of Advertising and Visual Publicity (DAVP) is the multi-media advertising agency of the Government of India.91 It caters to the publicity requirements of different ministries, departments, public sector undertakings, and autonomous bodies of the government of India.92
Structure. The DAVP has different departments dealing with the varied publicity needs of the ministries. Some of its subdivisions are the campaign wing, advertising wing, printed publicity wing, and audio-visual wing. Every government department that needs to advertise can approach the DAVP with its requirements. The DAVP then provides free design advice and helps the client to select the appropriate medium for publicity. The guiding principle for selection is maximum reach with minimum cost. The DAVP empanels various advertising agencies to assist with this process. In certain cases, the DAVP also has the right to advertise proactively based on its mandate.
Selection Criteria. The selection of newspapers/journals that will receive government advertising is made by DAVP. It empanels newspapers based on the guidelines laid out in the Advertisement
91 92
Ministry of Information and Broadcasting, “Outcome Budget 2009-2010,” Government of India, New Delhi. Directorate of Advertisement and Field Publicity. 42
Policy of the Government of India and negotiates a contract rate—for both classifieds and advertisements—with them on behalf of the government. More than 2500 newspapers/journals in Hindi, English, and other regional languages are on DAVP’s panel. Certain regional language publications get concessions in terms of required circulation, number of years of existence and so on to promote growth and development of regional newspapers.93
Other Relevant Information. The ministries and other government departments are entitled to advertise through other agencies not affiliated with the DAVP. However, these agencies need to offer rates similar to the ones that DAVP does. However, in most cases, that is not possible since the DAVP can bargain for the most competitive rates.
Accountability. DAVP activities fall under the Indian government’s Right to Information Act. Any citizen of India is entitled to request the DAVP documents for perusal and questioning. If a citizen or any party interacting with DAVP has a complaint, there is a grievance redressal office in charge of addressing and resolving the problems. The DAVP also maintains a Citizen’s Charter—both in print and online—that highlights the mission, vision, and activities of DAVP. It also produces an annual report of its activities that is available on the Website.94
Mass Mailings The Mass Mailing Department maintains lists of the addresses of 151,00,000 citizens of India. These are further subdivided by area of information being mailed out. Recent topics on mass mailing lists include the speeches of the current prime minister of India (mailed out to heads of schools and universities, all local libraries, voluntary organizations and newspaper editors), information regarding the government’s Family Welfare Program (mailed out to health workers, heads of NGOs working in the field of health, and so on).
The mass mailing wing is under the guidance of DAVP. The mass mailers include advertisements through flyers or other printed literature pertaining to government policies, programs, and achievements of central government and can include photographs of the prime
93 94
“Citizen Charter, Directorate of Advertising and Visual Publicity,” http://www.davp.nic.in/citizen_charter.htm DAVP Handbook. 43
minister and president. It distributes publicity material on the basis of instructions from the client department or as per the needs to the campaign.95 In order to ensure that this form of advertising is not misused, mass mailing is suspended once the Lok Sabha (Lower House) is dissolved up until the next elections are held.96
Mass mailing is a powerful advertising tool as it allows the government to customize the messages according to the population targeted. In a country with immense socio-economic disparities, this becomes a much more effective way of achieving impact than a general advertisement.
Directorate of Field Publicity The main objective of Directorate of Field Publicity (DFP) is to disseminate information about the government’s policies and schemes among the masses. The DFP also generates awareness about health, national integration, and other social issues among the target groups, mostly in remote places.97 The budget for the DGP during 2008–2009 was Rs. 149,00,000 (approx.. 327,005 USD), which was broken down into actual publicity materials, training workshops for employees, and purchase of new hardware, like projectors, computers, and other necessary equipment.98
A few examples of recent publicity campaigns by the DFP include a drive to get people out to immunization booths during the Pulse Polio campaign, a special publicity campaign on iodine deficiency disorder and its control measures, a drive to increase awareness in rural areas about the government’s rural schemes and programs, and several other initiatives.99
The DFP works at a more grassroots level in comparison with other departments under the Ministry of Information and Broadcasting. Equipped with men and material suitable for the job of delivering messages at the doorsteps of the people at the grassroots level, DFP field units
95 96
http://www.davp.nic.in/pdguidelines_new.pdf Ibid. 97 Ibid. 98 Ministry of Information and Broadcasting, “Outcome Budget 2009-2010,” Government of India, New Delhi. 99 Directorate of Field Publicity, “Monthly Highlights Report, February 2009,” Government of India. 44
endeavor to expose the masses to “the diverse socio-economic and cultural milieu of the country and inspire them to move ahead as citizens of the largest democracy in the world.”
The DFP also collects information/people’s reactions to the advertisements and conveys them back to the government. It is engaged in the task of publicizing various programs and policies of the government with its network of 207 Field Publicity Units and 22 Regional Offices.100 Broadly, the aims and objectives of the DFP are: • To project the policies and programs of the government by bringing its men and material face to face with the people and to inform them about the plans and schemes formulated for their benefit. • To educate people about the fundamental national values, like democracy, socialism, and secularism, and to reinforce their faith in them through constant personal contact. • To establish rapport with the people at the grassroots level for their active participation in the developmental activities as also to mobilize public opinion in favor of implementation of welfare and developmental programs. • To gather people’s reactions to the programs and policies of the government and their implementation down to the village level and to report them back for appropriate action by the government. The directorate thus works as a two-way channel of communication between the government and the people.
The DFP not only serves the needs of various ministries and government departments but also works with international organizations such as UNICEF, WFP, and so on. It does not charge for its services but is allocated funds directly through the government budget and occasionally supplements this with fundraising events.
In 2008–2009, the DFP had organized 10,502 special publicity campaigns, showed 34,060 public service films, and arranged 23,512 outreach tours to remote areas in the country.101
“Directorate of Field Publicity, Ministry of Information and Broadcasting,” http://india.gov.in/outerwin.php?id=http://dfp.gov.in/ 101 Directorate of Field Publicity, “Review of Past Performances,” Government of India. 45
100
Publications Division The Publications Division is one of the largest publishing houses in the country. It is primarily concerned with preserving national heritage and disseminating information through the production and sale of low priced, quality reading material on subjects of national importance. Most of the books it publishes are on topics that are not covered by other commercial publishing houses.102
However, besides books, the Publications Division brings out twenty-one journals on issues of national importance and social purpose, which are relevant to public service advertising and also occasionally carry tender notices and other government advertisements. Some of the key examples are the following.
Ajkal, the prestigious literary magazine in Hindi and Urdu, brings out a number of special issues and covers different aspects of Indian culture and literature. Ministries that are connected with these topics—like the Tourism Ministry—use this as a platform to advertise. Yojana, the flagship journal of the division, seeks to carry the message of planned development to all sections of society and serves as a forum to promote a healthy discussion representing a cross-section of views on socio-economic aspects of development. Yojana, which is published in thirteen languages, presents an all-India perspective while highlighting regional development, innovations, and initiatives.
Kurukshetra, the journal on rural development is serving as a forum for exchange of ideas on programs, policies, and implementation status of development efforts in the rural sector. Fertilizer subsidies, rural infrastructure projects, and other similar matters are advertised in such publications.
Employment News/Rozgar Samachar, published in English, Hindi, and Urdu every week is the largest circulated career guide in India. It carries information about job vacancies in central/state
102
Ministry of Information and Broadcasting, “ Outcome Budget 2008–2009,” Government of India. 46
government departments, public sector undertakings, educational institutions, and reputed private organizations. Its editorial pages include a lead article, diary of events, letters to the editors, quotations, articles on the world of science, besides those on career guidance and other matters of use to examinees.103
The books and journals are sold through dedicated shops called “Sales Emporia” in major cities, like Mumbai and New Delhi.104
To keep pace with technology, Publications Division is now starting to publish online. Employment News has also launched an interactive career oriented Website under the domain www.employmentnews.gov.in. The Website has a page hit of more than 3,00,000 users per day and a budget of Rs. 6,00,000 (approx. 13,168 USD) annually. They also try to provide erecruitment solutions through an interactive Website.105 The government policy on advertising online is still in an early stage. On the one hand, the Indian government struggles with defining Internet censorship and on the other with preserving democratic values.
Press Information Bureau The Press Information Bureau (PIB) is the agency of the Government of India to disseminate information to the print and electronic media on government policies, program initiatives, and achievements. It has a budget of approx. Rs.1628,00029 (approx. 3,572,923 USD). Functioning as an interface between the government and the media, PIB also provides feedback to the government as reflected in the media.106 It is responsible for the brand management of the Indian government via press releases and features, press briefings, press conferences, and conducted tours.
“Publications Division, Ministry of Information and Broadcasting,” http://publicationsdivision.nic.in/emp_show.asp?id=1 104 Ministry of Information and Broadcasting, “Outcome Budget 2008-2009,” Government of India. 105 “Citizen Charter, Publications Division, Ministry of Information and Broadcasting,” http://publicationsdivision.nic.in/others/citizen-charter.pdf 106 http://www.indiaprwire.com/misc/pib.htm 47
103
The PIB also accredits Indian and foreign media representatives, news cameramen, and technicians. In March 2009, 1,586 correspondents and 474 cameramen were accredited by the bureau’s headquarters besides 152 technicians and 85 editors/media critics.
All India Radio All India Radio covers 99.14 percent of the population and 91.79 percent of the area of the country with 231 broadcasting centers and 372 terrestrial transmitters, including 170 FM transmitters in twenty-four language and 146 dialects nationally. Its primary role is of a national public service broadcaster. It is mandated to pay special attention to niche areas of the governmental agenda. Some examples are the fields of education and spread of literacy, agriculture, rural development, environment, health, and awareness about women’s issues. Amongst all the different departments under MIB, radio (AIR) and television (Doordarshan) are the two that focus more on promotion of culture and ideals. The messages are crafted with the intention of promoting national integration and harmony, fight social evils, and impact social transformation. “Bahujana Hitaya, Bahujana Sukhaya,” i.e., to promote the happiness and welfare of the masses through information, education and entertainment is the main mission of AIR.
Tenders All government contracts are advertised as tenders in the open market in India. Each ministry or department is expected to follow detailed guidelines in inviting contractors to bid. The MIB assembles all tenders from various ministries and makes them available online. A special Website has been created that can be accessed by vendors globally. Each ministry also advertises —via DAVP—tenders in regional and national newspapers as per requirements. Tenders are published in both English and Hindi and occasionally also in a regional language to ensure fairness and maximum reach.
48
Incredible India The “Incredible India” campaign, launched in 2002, was a major initiative by the Government of India, to promote India as a tourist destination.107 It is a notable example of the Indian government’s international advertising campaign.
Critiques Although there are several positive aspects of the Government of India’s media policy, there are several cautionary tales as well.
The Ministry of Information and Broadcasting suffers from the same bureaucratic problems that plague the rest of India’s massive governance machinery. First, bureaucratic functions of many departments often overlap, leading to repetition of work and redundancy of positions. Second, this redundancy and bureaucracy leads to lack of accountability and inferior work.
The outcomes of lapses due to bureaucratic departments can be demonstrated by the two recent mistakes in government advertising. The first was when the advertisement for Indian Railways showed Delhi as being a part of Pakistan. The second was the Incredible India campaign ad that showed an African elephant in an Indian biodiversity advertisement.108
Although sound policies might be in place, the mechanisms to measure the impact of these policies are not clearly laid out. There is no cost-benefit analysis undertaken to measure the impact of media spending. Hence, the changes in governmental policy are not made on an incremental basis after regular feedback but are made in a more ad hoc manner.
In certain cases, there are no clear guidelines set or distinctions made on certain policy clauses. For example, ownership requirements of media (Indian vs. foreign) for empanelment with DAVP is not articulated in any of the organization’s materials.
http://www.icmrindia.org/casestudies/catalogue/Marketing/MKTG122.htm Priscilla Jebaraj, “African jumbo in Incredible India Ad,” http://www.thehindu.com/news/national/article799389.ece
108
107
49
The DAVP has also been criticized for using public funds to aggrandize historic political figures. In selecting these figures, no rationale has been provided or set process defined. Often the political party in power seems to influence the selection, which can lead to distortion and manipulation of public opinion. A recent example showed that the DAVP has spent nearly Rs 3 crore (approx. 600,000 USD) over a period of two months on advertisements to glorify late prime minister Rajiv Gandhi as against only Rs 87 lakh (approx. 175,000 USD) over a period of ten years for former Lal Bahadur Shastri, who enacted far more legislation in India.109 These full-page newspaper advertisements—usually bearing a photograph of Mr. Gandhi—do not carry any public service message, are not commemorating any occasion (his birth date, death anniversary, or something similar). They are simply the creation of idols in print. Since there were no set guidelines for media spending, the DAVP is not immune from pressure by its political masters.
In summary, for any policy to be effective, the loop needs to be closed. Strategy needs to be followed by action, measurement of impact, feedback, and restructuring of strategy.
Conclusion India is the world’s most populous democracy and South Asia’s dominant economy. The combination of its unique demographic makeup, political system, and colonial history makes it the ideal nation-state for Bhutan’s nascent democracy to emulate.
The Royal Government of Bhutan (RGoB) maintains strong ties with the Government of India (GoI); Indian military bases within Bhutan provide security; the Indian government covers Bhutan’s budget deficit; India is Bhutan’s largest trading partner and accounts for 98 percent of its exports and 90 percent of its imports;110 and the Bhutanese Ngultrum is pegged to the Indian rupee, with rupees in free circulation in Bhutan.111
109 110
Press Trust of India, “3 Crores in 2 Months for Rajiv Gandhi Ads,” NDTV, Friday January 29, 2010, New Delhi. Jay Shankar and Bibhudatta Pradhan, “Singh Visits Bhutan to Show India Backs Its Democratic Changes,” Bloomberg News, May 15, 2008. 111 “CIA World Factbook – Bhutan,” https://www.cia.gov/library/publications/the-world-factbook/geos/bt.html 50
As such, the GoI’s advertising policies offer a relevant template for the RGoB to formulate an advertising policy unique to Bhutan’s needs.
As Bhutan embarks on a development program fueled by hydropower exports, the RGoB can learn from the methods used by the GoI to adapt its advertising policy to a similar economic expansion that India has recently experienced. India can also offer lessons on pitfalls to avoid while formulating policies—the GoI’s media strategy seems to be heavily influenced by a political structure built on a patronage system. This system seems to breed corruption and inefficiencies. Being a nascent democracy, Bhutan can install the checks and balances now to avoid such disastrous outcomes in the future. By Sankalpa Dashrath [email protected]
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Public Advertising Case Study 4: South Africa
Executive Summary South Africa’s transformation into a democratic state in 1994 provided the opportunity and challenge for President Nelson Mandela to unify a country that had been divided along racial lines for forty-six years. Since then, South Africa has consciously worked to improve communication between the government and rural and underserved populations. Awarding government grants to media outlets that promote diversity and facilitate communication with underserved populations has been a success; however, their attempts to subsidize the press through advertisements has failed because of the propensity of corruption by government officials.
Media and Advertising Policy The Government Communication and Information System (GCIS) directs government media, and adverting policy is directed by it. Its purpose is to provide a “comprehensive communication service on behalf of government to facilitate the involvement of the majority of South Africans in governance, reconstruction and development, nation building and reconciliation.”112
Their main work consists of: serving as a media liaison and coordinating the media strategy across the government, monitoring domestic and international media coverage of government policies and programs, providing both in-house communication services and outsourcing where appropriate, marketing South Africa internationally, promoting local media development and diversity, producing magazines on socio-economic issues, and other opportunities.113
South Africa produces most of its government advertisements in-house through the Communication Service Agency (CSA). In 2008/2009, the government spent 20.8 ZAR or (2.9 million USD) on advertising. The CSA is specifically tasked with: 1. Creating advertisements. The CSA is tasked with marketing, product, and content
development. The CSA’s budget for 2008–2009 was 41,385,000 ZAR (6,108,036 USD) Their
112 113
http://www.treasury.gov.za/documents/national%20budget/2010/ene/vote08.pdf Ibid. 52
marketing section manages government’s corporate identity; develops strategies for marketing campaigns, events management, public relations campaigns and advertising; manages government’s communication distribution network; and provides a media bulk buying service. According to the GCIS, the focus of government advertising and campaigns “should be on messages that enable the public to participate in democracy and improve their lives.” While crafting campaign messaging, the heads of communication (HoCs) must abide by the following guidelines: a) promote behavior or attitudes that are generally regarded as being in the public interest, i.e. that will lead to improved public health and safety or quality of life b) promote public awareness and compliance with legislation c) raise awareness of government services available to the public or target audience d) encourage public use of government products and services e) promote public awareness of rights, responsibilities, duties or entitlements f) encourage public involvement in government decision-making g) inform the public of new, existing or revised government policies, programmes, initiatives or events h) promote public well-being, safety and order in the event of a crisis or emergency i) report on government performance in service delivery to facilitate accountability to the public j) encourage community pride, spirit, tolerance or assist in the achievement of a widely supported public policy outcome k) recruit staff, publish important statutory information and promote business opportunities with the department concerned.114
As for what not to do, the GCIS specifies that public advertisements must not: refer to any political party, use any political slogans, or promote any one individual (such as a minister).115 Each department has an HoC who is responsible for the implementation of marketing and advertising campaigns and must follow the guidelines dictated by the GCIS. All departmental
114 115
http://www.gcis.gov.za/resource_centre/guidelines/comm-pol-guide2010.pdf, 12. http://www.gcis.gov.za/resource_centre/guidelines/comm-pol-guide2010.pdf, 14. 53
marketing campaigns must be based on a GCIS-approved marketing strategy. While creating a media strategy, the HoC will consult with the GCIS as they have a database of appropriate agencies. A copy of the approved campaign marketing strategy must be submitted to the GCIS at least ten working days prior to the planned implementation for multimedia advertising campaigns exceeding 1 million ZAR (143,113 USD), and at least two working days for standard advertising campaigns.116 During this time, the departments must not commit to any costs or obligations in terms of the proposed campaign until it has received written approval of the marketing strategy from the GCIS. “The right of final approval for media placement and campaign content rests with the GCIS, which will take all aspects addressed in these policy guidelines into careful consideration when assessing the suitability of departmental marketing campaigns for implementation.”117 This process places a lot of power in the GCIS. As such, it is important that the GCIS be comprised of a diverse body of individuals, who are not susceptible to political whims.
In 2010, the GCIS was further tasked with crafting communication to speed up “economic growth, improve the health profile of all South Africans, intensify the fight against crime and corruption, and boost international cooperation by supporting communication about international forums.”118 As this has just been mandated by the government, it is unknown whether or not they have accomplished these goals yet.
Development and Empowerment of Local and Rural Communities Since 1994, the South Africa government has made a concerted effort to improve the economic standing of formerly impoverished communities. Many of the poorer communities are in rural areas with little access to media and government resources. As a result, the GCIS has created several initiatives to improve their ability to access information and government services: the Media Development and Diversity Agency, Thusong Service Centers and the Vuk’uzenzele Magazine.
116 117
http://www.gcis.gov.za/resource_centre/guidelines/comm-pol-guide2010.pdf, 13. Ibid. 118 Ibid. 54
Media Development and Diversity Agency (MDDA) Local media was strengthened in 2003 through government and private sector partnership known as the Media Development and Diversity Agency (MDDA). The MDDA was formed to create an environment for media development and diversity that is conducive to “public discourse and which reflects the needs and aspirations of all South Africans; redress exclusion and marginalization of disadvantaged communities and persons from access to the media and the media industry; promote media development and diversity by providing support primarily to community and small commercial media projects.”119
The MDDA defines community media as “any media project that is owned and controlled by a community where any financial surplus is reinvested in the media project.”120 The MDDA fund projects that add to media diversity are sustainable, promote a culture of reading, and involve the community.121 Since inception in 2004, the MDDA has supported more than 323 community and small commercial media projects (both broadcast and print), with approximately more than R118m in grants.122 It should be noted that this is six times more than the government expenditure on advertising, exemplifying the government’s commitment to the development of underserved communities.
A nine-person board runs the MDDA. The president, on the recommendation of the National Assembly, appoints six members, and the law mandates that the public be involved in the nomination process. One can see calls for nominations on their Website once terms are over; the short-listed candidates are published as well. They are nominated on the principles of fairness, freedom of expression, openness, and accountability; and they must uphold the Constitution and the other laws of the republic. Three members are appointed by the president, of which one must be from the commercial print media and another from the commercial broadcast media.123 With such an open and inclusive board, the awarding of grants has become less susceptible to political manipulation than the government placement of advertising in the press.
http://www.gcis.gov.za/resource_centre/public_entities/mdda_legislation/a14-02.pdf MDDA application guide. 121 http://www.mdda.org.za/brochure/Brochure(eng).pdf 122 http://www.mdda.org.za/themdda-MediaReleases.htm 123 http://www.gcis.gov.za/resource_centre/public_entities/mdda_legislation/a14-02.pdf, 7.
119 120
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“In a nutshell, MDDA has helped many projects get off the ground and others to survive crises, but medium term sustainability remains a challenge,” said Guy Berger, a board member of the MDDA and the head of the School of Journalism & Media Studies at Rhodes University, Grahamstown. According to Mr. Berger, the African National Congress (ANC), as a party, has urged government to increase funding to MDDA. Mr. Berger further specified that this system is clearly preferable to using advertising as an incentive or a subsidy.124
Thusong Service Centers Thusong Service Centers, formerly known as Multipurpose Communication Centers (MPCCs), are established in local communities across South Africa to provide local residents with information, such as employment opportunities, housing projects, and programs. These centers are another government by the GCIS and are, according their Websites, “one stop centers for services and information.” As of March 2009, 137 Thusong Service Centers were in operation.125 The government’s goal is to establish a Thusong Service Center in each of the 283 local municipalities.126
Thusong Service Centers allow people to access easily government resources and maneuver through government bureaucracies. They are particularly useful in rural areas where distances are vast and travelling to urban centers to get services and information is expensive. For these reasons, Thusong Service Centers have been identified as the main way of implementing development communication.127 Methods to develop communication with poor and rural populations include: government material written in simple language and local languages, alternative methods for those who are illiterate such as drama, and community radio.128 One of the most beneficial outcomes of these centers is that they allow communication to flow two ways, from the government to the people and vice versa.
124 125
Interview with Guy Berger. http://www.thusong.gov.za/about/history/index.html 126 Ibid. 127 http://www.thusong.gov.za/faqs/index.html 128 http://www.thusong.gov.za/faqs/index.html 56
Vuk’uzenzele Magazine In an attempt to increase rural communities’ access to information, the GCIS launched Vuk’uzenzele Magazine in 2005. The GCIS produces and distributes Vuk’uzenzele Magazine twice a month in print, online, and in Braille. It provides citizens with information on socioeconomic and other opportunities and how these can be accessed. It has a print order of 1.6 million copies, which are circulated in all nine provinces, in large part door-to-door in deep rural, rural, and peri-urban areas. The magazine is published in all official languages, but the majority of the print-run is in English. In the year 2010, 4.7 million USD was allocated. Content includes “practical information on how to access and make use of socio-economic opportunities, government campaigns and programs, local government issues, community development initiatives and light, entertaining features.”129
Advertising Regulators Advertising in South Africa is self-regulated.130 The Advertising Standards Authority of South Africa (ASA) handles complaints about advertising that is considered to be unethical, untrue, or misleading.131 The primary purpose of the ASA is the regulation of commercial advertising, but it also applies “to advertisements by government departments and agencies and to those by other non-commercial organizations and individuals.”132
The ASA is an independent body set up and paid for by the marketing communication industry itself to ensure that its system of self-regulation works in the public interest. The ASA has a president independent from the industry. According to the ASA’s Website, “Advertising is a service to the public and, as such, should be informative, factual, honest, decent and its content should not violate any of the laws of the country.”133
As to what the ASA means by self-regulation, it states, “the three parts of the industry—the advertisers who pay for the advertising, the advertising agencies responsible for its form and
http://www.info.gov.za/vukuzenzele/ Adrian Hadland, Wesley Cowling & Bate Felix Tabi Tabe, Advertising in the News. (Cape Town, South Africa: HSRC Press, 2007) p 1. 131 http://www.ombudsman.org.za/content/default.asp 132 http://www.asasa.org.za/Default.aspx?mnu_id=13 133 http://www.asasa.org.za/Default.aspx?mnu_id=10#Rulings
130 129
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content, and the media which carry it—work together, to agree advertising standards and to set up a system to ensure that advertisements which fail to meet those standards are quickly corrected or removed.”
Though the ASA code calls for the labeling or identification of paid-for content, so as to not mislead the viewer/reader, these aspects are rarely enforced, especially in print media. If and when the line is blurred, people must submit formal complaints; however, this rarely happens.134 This dependence on complaints can be seen as a weakness or a strength. The ASA places the onus on the people to complain, and thus it necessitates an active and involved citizenry. In places where the population is illiterate or uneducated, this type of regulation would be ineffective. One problem with some print advertising in South Africa—as in many countries—is that the ads often look like regular content. Though some do use labels such as “Special,” “Advertorial,” or “Commercial Feature” to indicate to the reader when he/she is looking at an ad, sometimes it is not clear. For example, labeling a section “Special Feature” can be confusing to readers.135 As for government advertisements, they are always accompanied by a governmental logo.
According to ASA’s 2006–2007 annual report, only 1 percent of the 2,095 complaints were lodged against government advertisements.136 This shows that the GCIS has done a good job at vetting government advertisements and campaigns organized by the various government departments (or that people don’t bother, don’t know how to complain or didn’t realize something was amiss).
Problems with Government Advertising in the Press There is debate in South Africa media about the benefits and weaknesses of government support of the media. Some see the government as intrusive, reducing media’s independence; others view
134
Adrian Hadland, Wesley Cowling & Bate Felix Tabi Tabe, Advertising in the News. (Cape Town, South Africa: HSRC Press, 2007), 2. 135 Ibid. 136 http://www.asasa.org.za/ClientFiles/Pdf/ASA%20Annual%20Report_2007_2008.pdf, 18. 58
government involvement as helping build a united, inclusive nation around common values.137 What resounds through the debates is that government advertising is not the preferred way to subsidize the press.
One such critic, Guy Berger, chairperson of the board of a local newspaper, the Grocotts Mail, said, “Personally, I do not believe governments should use advertising as a tool for media support (or punishment).” Mr. Berger’s opinion stems from his experience at the Grocotts Mail where a local municipality boycotted the newspaper after unhappiness with coverage in 2007/2008. The newspaper is based in Grahamstown and has a readership of about 24,372 per week.138 For the duration of the boycott, communication between journalists and local government officials became somewhat hostile. The real victims were the people living in the communities as reports were often devoid of government official’s explanations. For example, journalists had more difficulty contacting government officials when reporting on various government services such as toxic water crises, power outages, dumping, and sanitation. During this time, the municipality would often decline to comment.139
This was not the first occasion that the government boycotted or threatened to boycott newspapers. Former Minister in the Presidency Essop Pahad threatened to exclude the Sunday Times from state advertising.140 Additionally, in 2008, the Dlambe municipality stopped advertising in Port Alfred’s weekly Talk of the Town (TotT) after it published a story in May about the municipality dipping into its “Pothole Fund” to pay for a new luxury mayoral car.141 As for the Grocotts Mail, they did not sit back quietly. They legally challenged the municipality on several counts:
http://www.wolpetrust.org.za/dialogue2003/DN102003duncan_paper.htm http://www.grocotts.co.za/ads 139 http://www.journalism.co.za/index.php?option=com_content&Itemid=100009&catid=165&id=1067&view=artice 140 http://nml.ru.ac.za/blog/guy-berger/2008/10/24/resources-about-government-advertising-boycotts-private media.html 141 http://nml.ru.ac.za/files/Advertising%20boycotts%20hit%20two%20local%20papers.pdf
138
137
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Violation of the Constitution: sections 16 (free expression); 7.2 (obligation to uphold rights); 152 and 195 (democratic, accountable and participative local governance);
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Violation of Municipal Systems Act (responsiveness, communicative, participative governance), and violation of Municipal Finance Management Act (supply chain management procedure); and Promotion of Administrative Justice Act (procedural fairness; good faith, good reason).142
•
With the possibility of going to court, the municipality backed down, resumed advertisements, and agreed to pay for all the legal costs of the Grocotts Mail.
According to Mr. Berger, the local municipality “is dominated by ANC party members, but there is nothing in the ANC’s media policy that proposes advertising as a political weapon. Instead, the party calls for engagement with the media.” Rather than using advertising as a political weapon, Mr. Berger, suggested the government use “self-regulatory bodies such as the Press Council to which complaints can be taken; the right to sue for defamation; the MDDA to promote more media at grassroots;”143 or approaching the Press Ombudsman.144 Tenders In South Africa, public sector procurement or government procurement is estimated to amount to approximately 14 percent of gross domestic product (GDP) (R 475.8 billion/68.35 USD in 2006/07), which amounts to about 9.56 billion USD.145 The South African Constitution provides that when organs of state procure goods or services, they must comply with five principles: fairness, equity, transparency, competitiveness, and cost-effectiveness.146 South Africa employs a policy of affirmative action to blacks in an effort to improve their economic status.147
A branch of the GCIS, known as the Supply Chain Management and Auxiliary Services, manages all government tenders, and all available bid opportunities above 500,000 ZAR
http://nml.ru.ac.za/files/Grocotts%20article%20in%20Sunday%20Times%2020%20Sept%202008.pdf http://nml.ru.ac.za/blog/guy-berger/2008/10/24/resources-about-government-advertising-boycotts-privatemedia.html 144 http://nml.ru.ac.za/files/Grocotts%20article%20in%20Sunday%20Times%2020%20Sept%202008.pdf 145 http://www.puk.ac.za/opencms/export/PUK/html/fakulteite/regte/per/issues/2006_2__Bolton_art.pdf 146 Ibid. 147 Copyright 1997 The PRS Group, Inc. The PRS Group / Political Risk Service November 1, 1997
143 142
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(~$74,000 USD) are published to its Website in a weekly bulletin every Friday.148 The subscription rates for the “Government Tender Bulletin” are R39.32 (5.63 USD) per annum and R45.99 (6.58 USD) per annum overseas.149 Rather than have sporadic tender placement, the weekly bulletin and subscriptions provide a central place where anyone can access it.
Naturally, there will be corruption. One of the most recent scandals involves ANC Youth League president Julius Malema. Citing official tender and government documents, the Sunday Times reported that Malema’s companies were awarded more than twenty contracts, each worth between R500 000 and R39m between 2007 and 2008.150 One of the companies, a small engineering firm, profited from more than R130m (18.6 million USD) worth of tenders in just two years. Mr. Malema then used these profits to pay for his luxurious lifestyle, particularly to finance two opulent homes. Malema’s case is still being investigated.151 In order to curb tender fraud, such as Malema’s, in public procurement, Minister of Finance Pravin Gordhan proposed levying penalties of up to double the value of a contract on those who obtain contracts fraudulently. In October 2010, he announced that the government was investigating a total of R25 billion (3.5 billion USD) of procurement and tender fraud.152 According to South Africa’s Government Website, other measures to curb tender fraud include: • • • Making public officials who assist in tender fraud liable for the resulting losses incurred by the government. Implementing measures to ensure that officials who have breached the buying rules remain under suspension while an investigation into them is under way. Revising procedures for the issuing of tax clearance certificates, so that the South African Revenue Service (Sars) can more easily check whether a bidder has the required tax compliance or not. Strengthening tax compliance measures associated with government procurement,
•
148 149
http://www.gcis.gov.za/aboutus/procurement/index.html http://www.info.gov.za/view/DownloadFileAction?id=133389 150 http://www.news24.com/SouthAfrica/News/Malema-profits-from-govt-tenders-20100220 151 http://www.mg.co.za/article/2010-06-28-malema-tender-probe-still-not-concluded 152 http://www.southafrica.info/business/economy/policies/minibudget2010d.htm 61
including the introduction of a withholding tax on payments made to businesses selling to the government.153
As these proposed changes were announced on October 27, 2010, it is still too soon to tell whether or not they have been effective. Despite this, it is important to note that the media was free and active in their reporting of Mr. Malema’s corrupt activities. However, if they had been funded through government advertisements, they may have been less inclined to report on them for fear of the government pulling out advertisments. The media’s independence from government advertising money has helped them increase government transparency by holding it accountable.
Branding South Africa As a fairly young democracy, South Africa is concerned about its image. According to the former minister in the presidency, Essop Pahad, in 2005, One of the greatest challenges South Africa has faced since we achieved freedom has been to engage with the international community on terms that promote our national interests … From a communications perspective, that has brought the challenge of closing the gap between negative perceptions of our new democracy and the reality of a country steadily undergoing reconstruction and development.154
The International Marketing Council of South Africa (IMC) was established in August 2002 by the GCIS to help create a positive and compelling brand image for South Africa. The GCIS, along with the South African Tourism and The Department of Trade and Industry, fund the IMC.155
From 2002 to 2005, the IMC has created 7,000 radio advertisements, which have reached 94 percent of South Africa’s adult population, and over 560 television advertisements.156 They
Ibid. Africa News April 17, 2005 Sunday South Africa; Positive Image of Our Country Crucial, Says Pahad. (http://allafrica.com/stories/200504180532.html) 155 http://www.brandsouthafrica.com/who-we-are/427-stakeholders.html 156 Africa News April 17, 2005 Sunday South Africa; Positive Image of Our Country Crucial, Says Pahad. (http://allafrica.com/stories/200504180532.html)
154
153
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created the popular advertisement “Today I Woke up in South Africa” and broadcasted it on local television stations. You can view the advertisement online at the following location: http://www.youtube.com/watch?v=0wEYKyK9z64.
The IMC also advertises abroad. In London, they have branded taxis with the “South Africa Alive with Possibility” logo and interesting facts about the country.157 They have created a toolkit filled with materials for people to use when marketing South Africa abroad.158
Ubuntu To help create a South African style of advertising, the country employs the concept of Ubuntu, meaning humanity. Ubuntu is an Africa philosophical concept that has become one of the pillars of South Africa after apartheid. It has played a major part in nation building as it stresses the importance of brotherhood. Nelson Mandela described Ubuntu as A traveler through a country would stop at a village and he didn’t have to ask for food or for water. Once he stops, the people give him food, entertain him. That is one aspect of Ubuntu but it will have various aspects. Ubuntu does not mean that people should not enrich themselves. The question therefore is: Are you going to do so in order to enable the community around you to be able to improve?159 On any given day, more than three thousand commercial messages pass through South Africans’ minds. Jannie Ngwale, executive chairman of the advertising company, The Agency, believes that advertising agencies use Ubuntu when advertising. He said, This is a high point in South African advertising. We have arrived and so has the time; the time when the bulk of our advertising has a distinctly South African flavor; the time where consideration for—and empathy with—the audience creates communication that is deep, insightful, moving and, above all, human. When South African advertising talks with the spirit of (and not just about) Ubuntu, then we can stand proud. Our voice will be more frequently heard and, in this way, we will build a better life for the majority of South Africans.160
157 158
http://www.brandsouthafrica.com/marketing-materials.html http://www.brandsouthafrica.com/component/content/article/20/10-toolkit.html 159 http://www.youtube.com/watch?v=Dx0qGJCm-qU 160 Jannie Ngwale, “Advertising can enshrine Ubuntu,” Sunday Times (South Africa) Economy, Business & Finance, September 25, 2005, 7. 63
Country Background and Conclusion South Africa’s transformation into a democratic state in 1994 signaled the opportunity and challenge for President Nelson Mandela to unify a country that had been divided along racial lines for forty-six years. The task was challenging not only because South Africa is racially diverse, but also because it is linguistically rich. There are eleven official languages, including English, Afrikaans, Sesotho, Setswana, Xhosa, and isiZulu. Though English is most frequently used, according to the 2001 census, isiZulu is the most common home language and is spoken by nearly a quarter of the population. It is followed by Xhosa at 17.6 percent, Afrikaans at 13.3 percent, Sepedi at 9.4 percent, and Setswana and English each at 8.2 percent.161 Total adult literacy is 88 percent.162 The South African media became very important following the fall of the apartheid regime as the radio was used to broadcast the Truth and Reconciliation hearings. Using the African concept of Ubuntu, the Truth and Reconciliation commission called for victims’ families to face government officials who had committed violent human rights abuses against their loved ones in order to preserve the apartheid regime. If the former government official confessed and told the details of his crimes to the victim’s survivors, he would be granted amnesty. Though the process was difficult, it helped South Africans transcend the bitterness, hatred, and suspicion of the past and to make the transition to a more stable—albeit still imperfect—political order.
South Africa is by far Africa’s superpower; however, it still remains rife with problems. Unemployment is high, many South Africans remain poor, and it has the second highest number of HIV/AIDS patients in the world. 163
Though South Africa’s population is roughly seventy times as large as Bhutan, its continued goal to unify a diverse country around shared values such as Ubuntu is similar to Bhutan’s commitment to GNH.
161 162
http://www.southafrica.info/about/facts.htm#languages http://www.unicef.org/infobycountry/southafrica_statistics.html 163 http://news.bbc.co.uk/2/hi/africa/country_profiles/1071886.stm#facts 64
South Africa, like Bhutan is a fairly young democracy, faced with the task of unifying a country. Ubuntu has played a part in helping develop a South Africa style and philosophy to abide by. Though there are no clear policy prescriptions or outcomes from Ubuntu, it is something that is in the minds of marketers and the government when considering how to advertise.
Despite the positive message of Ubuntu, crime, aids, and poverty have made unifying the country difficult. Events like the World Cup helped bring the country together again, and South Africa should continue to ramp up efforts to promote Ubuntu where possible, particularly since the country is so racially, linguistically, and economically diverse.
With regards to government advertising, problems arose mostly in local municipalities. Based on the examples provided, they seem to be more likely to use government advertising as a political tool at a local level rather than at the national level. Fortunately, there were enough checks and balances in place for the newspaper to take action and bring abuses to the public’s eye.
A more effective approach than government advertisements in the media is the process of awarding grants through the MDDA. Not only does this encourage diversity and help start up media outlets, but it also avoids problems that arise from government officials’ political whims. The goal now should be to increase MDDA projects and see how small community projects can become sustainable community staples.
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(Note: Numbers in 2009/2010 are inflated due to the World Cup; as such, refer to 2008/2009 for more accurate numbers.) In 2008/2009, the GCIS spent a total of 20.8 ZAR (2.9 million USD) on advertising.
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By Michelle Moghtader [email protected]
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Public Advertising Case Study 5: United Kingdom
Executive Summary The United Kingdom has an extensive and largely successful public sector—one of the most notable in the developed world. Subsequently, their need for government advertising is much greater and, therefore, more cultivated. The multifarious objectives for their advertising and the ways in which it is achieved can be of great interest to any country developing a government media policy.
The country is recently emerging from thirteen years under the Labour Party (left-of-centre), with a new government led by the Conservative Party (right-of-centre). The current government is in the process of vastly cutting the public sector (with obvious implications on tenders) and, according the Cabinet Office, concurrently cutting government advertising and marketing by half. The previous year, however, under the Labour Party, the government was the UK’s largest advertiser, with a budget of ?500 million (800 million USD).164 Therefore, for the purposes of this report, the majority of the retrospective analysis will predate 2010.
The Digital Age of Tendering According to the treasury, the UK spends ?150 billion (240 billion USD) per annum on public procurement. It is important to note that the devolution of Wales, Scotland, and Northern Ireland from England, means that each of the four countries has its own tendering policies. Furthermore, the European Union laws and opportunities for public procurement also apply—this system is subsequently operating on two levels. The vast majority of information regarding tendering opportunities is to be found on the Internet. Given the often-composite nature of the application process, the Internet has proved to be a successful resource in easily providing guidelines. While technological accessibility or lack thereof remains a hindrance in Bhutan, this mode of dissemination is potentially feasible and advisable for larger, more complex tenders. Such jobs will most likely be offered to bigger, urban-based firms with readily available access to
“Government cuts shadow over ad market,” Financial Times, accessed October 18, 2010, http://www.ft.com/cms/s/0/897eaad0-da11-11df-bdd7-00144feabdc0.html 68
164
computers. For public tenders from EU institutions, there is a hardcopy circulation of the “Supplement to the Official Journal of the European Union.” There is also an online version of this publication, entitled Tenders Electronic Daily (to be found at: http://ted.europa.eu/TED/main/HomePage.do). According to the Website, “It is updated five times a week with approximately 1500 public procurement notices from the European Union, the European Economic Area and beyond.” One of the primary advantages of registering with the site and utilizing it (as opposed to the publication) is the efficiency it offers. The site exclusively allows businesses to “access the entire content of TED, including the archive. To personalise search profiles, according to your needs. To get e-mail alerts based on your search profiles.” For local and national tenders, there is much the same system. The primary source of information is the Internet. Each of the four countries’ governments issues its own Website. England has categorized the tenders into smaller contracts—?100,000 (160,000 USD) or less—and larger ones. In this instance, online advertising has proved to be the most efficient and transparent system. There is a Website for the former, defined as a “national lower-value contract opportunity portal” (supply2.gov.uk). For larger public procurement, there is a host of privately owned Websites, supplying information on opportunities—some of which provide hardcopy publications, which one may subscribe to. As part of its transparency efforts, the Office of Government Commerce (OGC has recently been absorbed into the Cabinet Office under the new Efficiency and Reform Group, established by the recently elected Conservative government) provides extensive information on the regulations that frame the tendering process. The space is designed to help suppliers by offering the same information the contractors use during procurement. There is extensive information on “Best Practice Guidance” for all types of contracts. It has been an excellent example of government transparency; as OGC states, “Government has set out the need for greater transparency across its operations to enable the public to hold public bodies and politicians to account. This includes commitments relating to public expenditure, intended to help achieve better value for money.” The subsequent impact on accountability has served to improve quality and “value for money” in the realm of public contracting. This method of dissemination is both highly recommended and easy to execute.
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Furthermore, this serves to open a gap in the market for advertising firms or, more specifically, the private sector to represent the government.
Using Social Media to the Government’s Advantage Policy regarding social media remains more fluid in its evolution, given the recent nature of the medium in comparison to TV, radio, and publishing. The UK government released a guide for its civil servants, irrespective of their department, entitled “Engaging Through Social Media,” produced by the Central Office of Information (COI). First and foremost, the government employees are informed to adhere to basic principles—they are to be “credible, consistent, responsive, integrated, a civil servant.” In elaborating on guidance for press officers, the report informs that they “should evaluate departmental initiatives discussed on social media applications and participate in debate about their organization’s decisions.” This provides a fruitful resource for feedback regarding governmental policy and its efficacy. Agents are told to monitor and evaluate relevant sites that target the departments’ key demographic segment by, for example, gauging “how effectively other sites engage your target audience.” They are to participate personally in order to gain a thorough understanding of how the Websites are used with the subsequent benefit of improving outreach. After cultivating a thorough understanding of a particular social media’s benefits and risks, only then are press officers encouraged to utilize the outlet. This mode of communication can be used for publishing necessary and/or urgent information and responding to questions from the general public. While it is not as feasible to publish longer documents, such as updated legislation, inquiries relating to such matters can allow the press officer to direct the public to alternative media outlets with more in-depth information. This is an example of why the engagement with the public in this capacity is argued to promote transparency.
The Met Office—a governmental department concerned with the weather—has impressively and efficiently optimized its outreach through social media. It has a clearly defined social media policy, which includes Facebook, Twitter, Flickr, and YouTube. Users of such sites, who are members of the Met Office’s “profile,” are informed they will receive between ten and thirty messages per week, the limit of which can be exceeded in extenuating circumstances. The public can benefit for a multitude of reasons. Advertising severe weather warnings, such as floods, can
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serve to help agriculturalists with their crop to save lives. Information on predicted snow levels during the winter has helped prevent motorist emergencies. More recently, Facebook and Twitter were used for statements and releases on volcanic ash: such information was a necessity for the millions of airline travelers affected, along with others dealing with the fallout’s various safety implications.
Furthermore, these outlets can also help refine policy development in all areas of government. Marketers are encouraged to “monitor social media for discussions about [their] organization, its proposals, campaigns, or the services it delivers.” Being able to locate specific demographics through such easily accessible means can be used to the government’s great advantage in measuring the need for certain strategies and the impact of existing policy—not to mention the government’s capacity to advertise campaigns while directing them at target audiences.
The success of this endeavor is clearly founded and relies upon 71 percent of adults having broadband.165 In excluded, rural regions of the country, the UK either subsidized or provided broadband to the denizens. Given the compelling reasons for using Internet-based mediums to achieve speedy and efficient dialogue with the public, the government may want to consider subsidizing technologic schemes that provide the rural population with either a phone or access to a computer. This would overcome the special barriers that hinder widespread circulation of printed press. In time-sensitive matters—for example, a government’s attempt at curtailing an epidemic—disseminating essential information could provide a return on the technological investment. In the case of public health related problems, successfully managing them can both prevent drainage of other governmental resources (healthcare) and maintain a healthy workforce.
Public Service Announcements The Department for Culture, Media and Sport has a representative committee in parliament that produced a report in April 2010. The committee turned to the Press Association in its search for proposals on public service reporting. Given that there is a growing pressure on printed press as it becomes increasingly under-resourced, the report found that newspapers were less inclined “to report on public institutions and local democracy.” Therefore, this gap in the market is used to
165
“Facts and Figures,” Office of Communications (Ofcom), November 2010. 71
both fulfill the need for regular reporting on public institutions through the placement of public announcements and support local media. Given the correlation between this financial strain and the shrinking readership, it remains an area which the government understandably intends on not investing a great deal of resources. Yet it remains useful knowledge for government to ensure that information regarding public concerns does not atomize in the printed press.
As is the case with many of the government’s schemes at information dissemination, the Internet has provided a centralized forum for public announcements of all sorts; these can be found on one site: direct.gov.uk. Some of the myriad topics covered include employment, health and wellbeing, home and community, and money, tax and benefits. Key announcements and spending reviews of each topic can be found. The page is regularly updated with notifications and content regarding emergencies and is immediately circulated through other mediums, too, such as radio and television.
Government Jurisdiction in Times of Emergency In cases of emergency, the government maintains the power to “to require suspension or restriction of a provider’s entitlement.”166 The secretary of state has reasonable grounds to interfere with broadcasting in cases where there is a threat to national security, public health, and public safety. This interference is defines as “a direction that the entitlement of the relevant provider to provide electronic communications networks or electronic communications services, or to make associated facilities available, is suspended.” The order of suspension or restriction then comes from the Office of Communications (Ofcom). Under most circumstances, this department is to take the orders of the secretary of state; however, Ofcom retains discretionary power.
If the government requires that a communications service “make
166
“Communications Act of 2003,” The National Archives, 2003. 72
such powers to its advantage—be it propagandist intentions or campaigning—having such systems in place can help ensure this does not ensue.
Public Broadcasting There are numerous public broadcasting outlets in the form of Internet, radio, and TV, while none of the main publications have any formal affiliation with the government. According to the Department for Culture, Media and Sports, there are three public service television broadcasters: the BBC, Channel 4, and S4C. The BBC is broadcast nationally and is funded primarily by the television license fee, compulsory for anyone owning a television. Channel 4 is also a nationally broadcast public corporation; however, it is self-funded through advertising. Wales—devolved from the central government—has its own equivalent of Channel 4, which is funded by both advertising and governmental grant-in-aid. While Channel 4 and S4C, however, are, in part, financed through private advertising, it is of interest to us to examine the ways in which the BBC differs from these channels.
Unlike its two other counterparts, the BBC is exclusively funded by the government, forgoing any commercial support. It has been highly successful in presenting itself as a unique example of objectivity, exempt from the pressures of the funding that many media firms find themselves under. The Office of Communications (Ofcom) is an independent body, responsible for licensing, regulating, and monitoring public service broadcasters. The BBC, furthermore, benefits from the regulatory intervention of a Royal Charter (this applies, too, to its radio and online content).
The BBC’s Royal Charter is updated every decade and is to be revisited in 2016. The purpose of it is to ensure that “the BBC shall be independent in all matters concerning the content of its output, the times and manner in which this is supplied, and in the management of its affairs.”167 The two governing bodies concerned with adhering to these guidelines are the BBC Trust and the Executive Board of the BBC. The Trust is concerned with setting the strategic direction of the organization and “exercising a general oversight of the work of the Executive Board.”
“Broadcasting: Copy of Royal Charter for the continuance of the British Broadcasting Corporation,” Department for Culture, Media and Sports, October 2006. 73
167
Essentially, the Trust serves to act in the interest of the public—in particular that of the licensefee payers. The Executive Board, on the other hand, concerns itself with operational management and adhering to the agenda created by the Trust. These were the priorities they set:
The Public Purposes of the BBC are as follows— (a) sustaining citizenship and civil society; (b) promoting education and learning; (c) stimulating creativity and cultural excellence; (d) representing the UK, its nations, regions and communities; (e) bringing the UK to the world and the world to the UK; (f) in promoting its other purposes, helping to deliver to the public the benefit of emerging communications technologies and services and, in addition, taking a leading role in the switchover to digital television.
It is essential to recognize that the two bodies are intended to function independently of one another.
Therefore, when the government intends on using the BBC for its own advertising purposes— e.g., public service announcements—it must get approval from the BBC for use of the public broadcasting services. It is precisely this level of distance between the government and its media which is desirable to avoid the dangers of having the two inextricably bound.
Conclusion The UK’s urban population is 90 percent of the total, which will be one of the most important differences to take into account when extrapolating from its advertising policy. Despite the substantial and fundamental differences between the United Kingdom and Bhutan, there is an argument to be made for using certain features of the government media policy in the UK when constructing a new policy elsewhere. As the country with the seventh largest gross domestic product, it can provide useful frameworks for those countries whose governments and economies are still being established. Perhaps most pertinent, its primary public broadcasting service, the British Broadcasting Corporation (BBC), is the largest broadcasting organization in the world.
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(According to an extensive 2004 study, there are approximately 150 million listeners to BBC World Service radio alone, which “equates to at least 50 per cent more listeners than any comparable international radio broadcaster.”168 At the time of the report, there were approximately 300 million monthly page impressions.) The UK’s extensive official media policy has been tried and tested, providing a clear outline of what has been successful for anyone wishing to adopt similar policies. By Natasha Noman [email protected]
168
“Press Releases: BBC World Service remains world’s leading international radio broadcaster,” BBC Press Office, June 21st, 2004. 75
Press Subsidies Case Studies
Press Subsidies Case Study 1: Canada
Canada Numerous funds managed by Canada’s federal culture ministry, the Department of Canadian Heritage, subsidize media production. In addition, the Canadian Radio-Television and Telecommunications Commission (CRTC) mandates programming quotas to encourage the production of news media in local communities. Moreover, the CRTC also taxes private cable companies to fund federal subsidy programs and requires private cable companies to demonstrate a quantifiable public benefit for mergers or acquisitions, some of which is redirected toward media production funds.
The Canada Magazine Fund (CMF) The Department of Canadian Heritage manages and funds this subsidy. The CMF aims to increase Canadian editorial content in magazines while strengthening the overall infrastructure of the industry. Although not chartered to support local or news content directly, because the CMF is open only to Canadian magazines, businesses, and associations, the CMF indirectly funds the production of local content and can additionally be used to subsidize the production of local news content. Four CMF programs provide funding. 1. Support for Editorial Content: Offsets production costs for Canadian magazines producing Canadian content. The funding received by each publication varies annually; it is calculated based on the proportion of a magazine’s claimed costs compared to the total application pool’s eligible expenses.169 2. Support for Arts and Literary Magazines: Functionally identical to the Support for Editorial Content, the SALM provides a special level of funding for magazines specialized in Canadian arts. 3. Support for Industry Development: The SID provides project-based grants to media associations in order to strengthen the competitiveness of the Canadian magazine
169
Support for Editorial Content: Applicant’s Guide 2009-2010. Canadian Heritage/Her Majesty the Queen in Right of Canada, 2009, 2. 76
industry. Grants are generally used to pay for business development, professional development, or training, to strengthen the distribution networks and infrastructure of associations, or to analyze industry trends. 4. Support for Business Development for Magazine Publishers: a project-based grant distributed to individual magazines to support their business development, professional development, training, or marketing projects. During the 2005–2006 fiscal year, the total budget for the CMF was 16 million CAD (15.6 million USD). This was divided as follows:170 Editorial Content $10 million (9.8 million USD) Arts and Literary Mag. $1 million (980,000 USD) Business Development $2.5 million (2.4 million USD) Industry Support $2.5 million (2.4 million USD)
The Canadian Television Fund The Canadian Television Fund (CTF) is a non-profit organization commissioned primarily to support the production and broadcast of Canadian television shows. The CTF is financed by the Department of Canadian Heritage and Broadcast Distribution Undertaking’s (BDUs—cable and direct-to-home satellite companies). The main program through which the CTF allocates funds is the Broadcaster Performance Envelope (BPE) stream. Eighteen percent of this funding stream is set aside to fund documentary productions.171 A BPE is the amount of funding a channel receives to support production. The amount of the support is determined by a complicated point system, which assesses broadcasters’ performance in relation to other channels applying for funding according to relative performance in four categories: audience success, historic access, regional production licenses, and aboveaverage licenses.172 In addition, the BPE allocated to each channel is subdivided and pegged to the production of either drama, children/youth, documentary, or arts and can only be used for the specific type of program designated.
170
Numbers and Issues: Annual Report 2005–2006, Canadian Heritage/Her Majesty the Queen in Right of Canada, 2007, 10-14. 171 Canadian Television Fund Stakeholders’s Report 2007–2008, 11. 172 Canadian Television Fund Annual Report 2008–2009, 120. 77
In 2009, the total amount of BPE financing for English-language productions was $134.7 million (131.5 million USD), while the total amount of money allocated by the CTF for all streams of subsidies in all languages was $283 million (276.4 million USD).173 This was funded by $182 million (177.7 million USD) from BDUs, as well as by a $119 million (116.2 million USD) grant from the Department of Canadian Heritage.174 The BDUs’ contribution is required by the CRTC. As a condition of their license, BDUs pay 5 percent of their gross annual broadcasting revenue to Canadian programming. At least 80 percent of these funds must go to the Canada Television Fund; this money is collected on a monthly basis by the CRTC and deposited into the fund.175
The Local Programming Improvement Fund (LPIF) Started in 2008, the CRTC’s Local Programming Improvement Fund (LPIF) subsidizes local television stations and supports the production of local programming in non-metropolitan markets. The subsidy is collected by the CRTC and distributed directly to local broadcasters. Its official objectives are: “1) To ensure that viewers in smaller Canadian markets continue to receive a diversity of local programming—particularly local news programming; 2) To improve the quality and diversity of local programming broadcast in these markets; and 3) To ensure that viewers in French-language markets are not disadvantaged by the smaller size of those markets.”176 In order to be eligible for a LPIF grant, a station must be based outside a city and broadcast a minimum of seven hours of local programming per week.177 Local programming is defined as “programming produced by local stations with local personnel or programming produced by
173 174
http://www.broadcastermagazine.com/issues/story.aspx?aid=1000090726 Canadian Television Fund Annual Report 2008-2009, 19. 175 The remaining 20 percent can be distributed directly by the BDUs to independent broadcasters or to other funds that support Canadian programming. 176 http://www.crtc.gc.ca/multites/mtwdk.exe?k=glossary-glossaire&l=60&w=42&n=1&s=5&t=2 177 http://www.cab-acr.ca/english/television/lpif/default.shtm 78
locally-based independent producers that reflects the particular needs and interests of the market’s residents.”178
Taxes collected from BDUs fund the LPIF. Therefore, the amount of money available for LPIF subsidies depends on the BDUs’ taxable earnings. In 2008 (the first year of the LPIF), the CRTC ruled that the contribution of these companied should be 1 percent, which brought the total amount of the fund to $68 million (66.4 million USD). For 2009, the BDUs’ contribution to the LPIF was temporarily raised to 1.5 percent of their gross revenue, and the CRTC has announced that the fund is projected to collect slightly over $100 million (97.7 million USD).179 The first third of the fund is distributed by the CRTC equally among all eligible local producers who apply. The remaining two-thirds is distributed based on how much local content was logged over the last three years by these stations.
Canadian Content Requirements (CanCon) and Local Content Quotas The CRTC obligates all licensed broadcasters to maintain quotas of Canadian programming, a requirement nicknamed “CanCon” (Canadian Content). Under current CanCon requirements, 60 percent of all programming between 6:00 a.m. and midnight and 50 percent of primetime programming aired between 6:00 p.m. and midnight must be Canadian. To be considered Canadian, a program must either be certified as such with the CRTC, or it can be automatically counted toward CanCon requirements if it is a news or public affairs program.180
These content requirements impact the provision of news throughout the country by creating incentives for broadcasters to air local news, which is far less costly to produce and less onerous to register than Canadian dramas or arts shows. Because news is considered by definition Canadian, news, current affairs, and talk programs have historically filled much of the CanCon requirement.
178
http://www.cab-acr.ca/english/television/lpif/default.shtm#7 These are the criteria in English-language markets. In French-language markets, the weekly quota is reduced. 179 http://www.channelcanada.com/Article3126.html 180 http://www.crtc.gc.ca/eng/info_sht/tv11.htm. 79
In 2009, as a result of the economic downturn and the desire to ensure the continuation of local programming, the CRTC imposed additional local programming quotas as a requirement for licensing. In English-language markets, the minimum local programming levels for 2009–2010 are fourteen hours per broadcast week in metropolitan markets and seven hours per broadcast week in non-metropolitan markets.181
Public Benefits Test The CRTC approves proposals for the transfer of control or ownership of BDUs. As one of its requirements for acceptable transactions, the CRTC demands that the parties involved in mergers and acquisitions demonstrate the public benefit that will stem from their deal. Although there is no set amount required for this public benefit, generally proposals should show that 10 percent of the value of the transaction will go toward the public’s benefit. This is called the “benefits test.”
Tangible benefits generally include operating expenditures, such as staff or programming improvements, capital expenditures for technical improvements, or grants made to Canadian talent or program development funds.182 These grants can and sometimes do subsidize news and media production.
Proposals are assessed on a case-by-case basis. In the majority of cases denied by the CRTC, lack of sufficient public benefits was the main cause. However, as previously stated, the 10 percent benefits level is merely a guideline. This can clearly be seen in the summary of these public benefits described in the following chart:
181 182
http://www.cab-acr.ca/english/television/lpif/default.shtm http://www.crtc.gc.ca/eng/archive/1993/pb93-68.htm 80
Public Benefits since 1985–86183 Cable TV # of transactions Value/cost of transactions 48 $842,586,000 (822,837,469 USD) Value of total benefits % value of benefits (average)184 Range of benefits By Cara Haberman [email protected] 2.4%-37.1% 7.3%-49.9% 0%-23.3% $97,926,000 (95,630,810 USD) 11.6% Television 14 $882,577,000 (861,891,160 USD) $162,412,000 (158,605,387 USD) 18.4% Radio 79 $409,823,413 (400,217,971 USD) $58.3 million (56.9 million USD) 14%
183 184
Ibid. As percent of purchase price of transaction. 81
Press Subsidies Case Study 2: Sweden
Sweden Sweden does not provide subsidies for radio or broadcast or cable television. However, Swedish newspaper subsidies have existed since the beginning of the 1970s. The Press Subsidies Council is the government agency responsible for allocating these state subsidies to publishers.185 In allocating funding, the council applies different funding regulations to high- to mediumfrequency publications (published three to seven times per week) than to low-frequency papers (one or two times per week). Swedish newspaper subsidies are primarily allocated for production or distribution efforts. Production subsidies are given to “second” newspapers, i.e., newspapers that have a competitor with a higher circulation in their place of publication. In 2007, the total newspaper production subsidy amounted to 433 million SeK (Swedish Kronor).186 Distribution subsidies are granted for cooperation in newspaper distribution on condition that at least two daily newspapers collaborate. They represent a modest infusion of capital: 10 oere (one-half of one cent) per paper distributed, or around 3 to 5 percent of total distribution costs.
While political support for scaling back or ending the subsidies seems to be minimal within Sweden, the European Commission recently told Sweden gradually to cut subsidies to big metro newspapers or face a formal state probe. This complaint was made on the grounds that aid distorts competition.187 A further inquiry into whether the subsidies operate in accordance with community law was triggered by a complaint from a Swedish media group, Bonnier, that competes with two subsidized dailies within Sweden. The complaint was filed with the European Union. Commenting on the investigation, EU Competition Commissioner Neelie Kroes said, “The commission recognises the importance of media pluralism for the cultural, democratic and public debate in member states and the importance of newspapers in this context, however,
http://www.sweden.gov.se/sb/d/3011/a/19032 http://reutersinstitute.politics.ox.ac.uk/fileadmin/documents/Publications/Press_Subsidies___Local_News_the_S wedish_Case_Final.pdf 187 http://europa.eu/rapid/pressReleasesAction.do?reference=IP/09/940
186
185
82
running a newspaper is also a commercial activity and the commission has a duty to prevent undue distortions of competition and trade resulting from public subsidies.”188
Some implied concerns about news subsidies are that they further centralize government authority and that newspapers would be less likely to criticize a government that subsidizes their expense. However, one survey of Swedish newspaper editors found just the opposite: newspaper editors were still willing to criticize “the government in the papers, even though they are supported by subsidies.”189
More commonly, arguments and debates center on the free-market implications of newspaper subsidies. However, in the case of Sweden, the market response to Swedish newspaper subsidies has been relatively positive. There has been no clear market pushback against the subsidies, in part, because Sweden has carefully framed the rationale for funding in market-friendly terms such as “competition, choice, and diversity.”190 Nevertheless, a theoretically strong general argument against the subsidies would highlight the costs of the market-inefficiencies protectionism produces: as the government is subsidizing companies that might otherwise fail, a market argument could be made that subsidies incentivize inefficiency or, at the very least, lessen the “market-appropriate” punishment for said inefficiencies.
Despite this inefficiency argument, the market-friendly framing of the Swedish government is more than just semantics. In fact, it points to four market-focused rationales to justify the funding program. First, the Swedish news subsidy model lowers barriers to entry. Normally, a newcomer paper with a business model reliant on advertising would need to rapidly acquire readership. This task is difficult. However, by providing production supports to low-coverage papers to offset this missing advertising revenue, subsidies help these potentially viable newcomer papers survive their infancy. And by increasing competition, the argument goes; this policy tends to increase aggregate content diversity and consumer choice within the Swedish newspaper industry.191
http://europa.eu/rapid/pressReleasesAction.do?reference=IP/09/940 http://www.eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailmini.jsp?_nfpb=true&_&ERICExtSe arch_SearchValue_0=EJ294688&ERICExtSearch_SearchType_0=no&accno=EJ294688 190 http://jci.sagepub.com/cgi/reprint/33/4/376 191 http://www.regeringen.se/content/1/c6/01/90/32/c6a0f7aa.pdf
189
188
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Second, the model creates benefits associated with economies of scale. For low-coverage and newcomer papers, distribution costs are generally the greatest obstruction to market entry. This model permits these smaller papers to profit from the high-coverage newspapers’ benefits of scale. High-coverage papers also benefit because demand (and revenue) for their underutilized capacity increases.192
Third, the subsidies reduce overall costs to society as the cost of subsidizing a paper is less than the price of founding and starting a new one. None of the Swedish low-coverage newspapers that has gone out of business has been successfully revived, despite several attempts to do so. The lesson learned is an ounce of prevention is worth a pound of cure.193
Finally, by incentivizing competition, the Swedish subsidy model decreases the likelihood of local newspaper monopolies. Monopolies tend to put upward pressure on the price advertisers and consumers pay (particularly in Sweden where the consumer demand for newspapers is fairly inelastic) while simultaneously decreasing the diversity of content. Subsidies that target second papers may therefore help prevent the formation of monopolies that distort an otherwise wellfunctioning free market.
In considering the Swedish model in the context of a prospective US subsidy model, the following considerations should be kept in mind: (1) voter turnout is very high, 78 percent in the 2006 election; (2) newspaper readership is very high, reaching 75 percent of households each morning; (3) Sweden spends approximately 61 SeK per person on newspaper subsidies (no hard figures appeared available, but dividing the 2008 distribution plus production figures by the CIA Factbook’s 7/08 count of 9,059,651 people194 gives this crude figure). Because voter turnout and newspaper readership are higher in Sweden than in the US, the risk of small political interests exercising influence beyond their numbers in the subsidy debate is less of a concern in Sweden than it should be in the US. By Rob Grabow
192 193
http://www.regeringen.se/content/1/c6/01/90/32/c6a0f7aa.pdf http://www.regeringen.se/content/1/c6/01/90/32/c6a0f7aa.pdf 194 https://www.cia.gov/library/publications/the-world-factbook/geos/sw.html 84
[email protected]
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Press Subsidies Case Study 3: The United Kingdom
The United Kingdom Like the US, the UK is currently undergoing a review of its media system with the intent of finding ways to support the continued production of high quality news. This process, called Digital Britain, was inspired by a study commissioned by Oxford University’s Reuters Institute for the Study of Journalism that argued in favor of funding news production.195 Like the Future of the Media project, the Digital Britain project starts with the premise that the economic foundations of news publishers are becoming increasingly unstable. This trend is particularly true “in local and regional markets” where information is “the lifeblood of a vibrant economy” and where “strong, viable and diverse news media is also integral to democratic life.”196 The Digital Britain report notes, “Digital Britain is at the beginning of a new and possibly disruptive wave of local news, generated by communities for communities using free online media. Over the medium term this has the potential to be good for local pluralism and expression as commercial funding for traditional media diminishes.”197 However, there is a concern that the current content revolution will “demolish existing structures faster than new ones come into being.”198 Therefore, as part of the Digital Britain project, the UK is currently seeking ways to “help the more traditional media in building bridges to the future.”199 The following provides an overview of some of these initiatives, as well as the flagship of the British news media funding system, the BBC license fee. The BBC Television License System200 In Britain, consumers must pay an annual fee to access television broadcasts. The annual household cost for color and monochrome television licenses are £145.50 and £49.00,
195
“Ch. 5 Public Service Content in Digital Britain,” Digital Britain-Final Report, Department for Culture, Media and Sport, June 2009, 15. Available online at http://www.culture.gov.uk/images/publications/digitalbritainfinalreport-jun09.pdf 196 Ibid. 197 Ibid., 16. 198 Ibid., 17. 199 Ibid. 200 http://www.tvlicensing.co.uk/easy-read/why-you-need-a-tv-licence-ea25 86
respectively.201 A single fee is assigned per household, so multiple televisions in a home could be covered by a single license. This licensing law applies not just to TVs but to any medium through which an individual watches television programming. For example, even if you watch TV on your laptop or mobile phone, you are required to purchase a license.
The proceeds from these licensing fees account for approximately 75 percent of the BBC’s £4,606 billion in annual operating revenue. The BBC’s second most important revenue source is commercial income—approximately 20 percent—followed by World Service and BBC Monitoring grants. Collectively, these funding sources pay for the BBC’s television, radio, and Internet services.202 The table below shows the allocation of the licensing fees. The £11.63 is the monthly cost of the licensing fee based on the 2009 annual license cost of £139.5. To the right is the percentage of the licensing revenue allocated to each of the platforms. Allocation of License fee:203 (based on 2009 license fee of £139.5/Year) Television Radio Online Digital Switchover/Other £8.00/£11.63mo £2.10/£11.63mo £.61/£11.63mo £1.01/£11.63mo 68.7% 18% 5.2% 8.6%
Local Content Requirements for Radio Until recently, Ofcom’s “localness” guidelines stipulated that FM stations be required to broadcast ten hours of locally made programs each weekday during daytime hours and four hours over the weekend. AM stations had to provide four hours every day of the week, while stations based in the so-called “nations” (Scotland, Wales, and Northern Ireland) supplied at least six hours of programming from their home nation.204
Interestingly, in April 2010, Ofcom announced that commercial radio stations will be allowed to reduce their local programming from ten to seven hours per day as a means of cutting costs and
201 202
http://www.tvlicensing.co.uk/easy-read/why-you-need-a-tv-licence-ea25 http://www.bbc.co.uk/annualreport/exec/financial/highlights/highlights.shtml 203 http://www.bbc.co.uk/aboutthebbc/licencefee/ 204 http://www.ofcom.org.uk/media/news/2008/02/nr_20080206 87
protecting broadcasts of local news.205 This will come into effect in May along with the new Digital Economy Act. Radio stations are having trouble meeting costs due to a decline in ad revenues: therefore, in exchange for their commitment to provide local news bulletins on weekdays, Ofcom agreed to this cut in their general local programming requirements. Broadcasters will also be allowed to co-locate and share all their programming to reduce costs further. These content requirements are opposed by commercial radio broadcasters, who argue that a) there should be no local requirements at all and b) if there are local requirements, they should be reduced.206 On the other side of the debate, groups such as the Campaign for Press and Broadcasting Freedom, the National Union of Journalists and Estuary Media want higher local content quotas.
Digital Britain Independently Funded News Consortia (in pilot stage) The Digital Britain bill “a) supports growth in the creative and digital sectors, b) tackles online piracy and c) supports the availability of public service content, especially local news.”207 In terms of achieving the latter, the bill proposed the creation of Independently Funded News Consortia (IFNC), “a consortia of parties who will collaborate to provide regional and local news services.”208
The official Digital Britain bill describes IFNCs as, “A joining of interested parties who will provide a more ambitious cross-media proposition and enhanced localness compared with current commercial television regional news; but which, to maximize audience reach, will also broadcast in the regional news slots in the schedule of current Channel 3 Licensees.”209 Currently the details about how this will occur are still in the works, but in general the IFNC model is intended to relieve the burden on public service broadcasters—particularly Channel 3—by
205
Mark Sweney, “Ofcom: commercial radio can slash local programming,” Guardian.co.uk. April 15, 2010. Available online at http://www.guardian.co.uk/media/2010/apr/15/commercial-radion-ofcom-local-programming 206 http://www.ofcom.org.uk/consult/condocs/futureradio07/statement/. Commercial broadcasters had been pushing for seven hours per week, a reduction goal that they achieve this month. 207 http://www.culture.gov.uk/what_we_do/broadcasting/5631.aspx/ 208 “Digital Economy Bill. Provision of News: FACTSHEET,” Crown Copyright, November 2009. Available online at http://www.bis.gov.uk/digitaleconomybill/ 209 Ch 5, Digital Britain, 22. 88
letting Channel 3 stop news provision.210 IFNC’s will provide the replacement news broadcasts using public funds and will function over a variety of platforms. These consortia will probably be composed mainly of existing television news providers, newspaper groups, independent production companies and other newsgathering agencies, that will be allowed to enter the consortia after being approved during a competitive bid process.211
The program is being implemented in order to assure continuing levels of regional and local news production. It is seen as necessary because Ofcom recently conducted a study that projected that Channel 3, which currently broadcasts regional news, would enter into deficit by 2011 and that this “deficit will reach £38-64 million in 2012.”212 Because regional news is Channel 3’s biggest public service broadcasting charge (estimated at £68 million in 2010), the IFNC project will help keep regional news production and Channel 3 alive.
Another justification for the subsidy is that consumers have consistently shown that they value and want local and regional news but that public service broadcasters like Channel 3 cannot sustain their current levels of programming.213 Therefore, there is a need for an alternative model. IFNCs are believed to “offer enhanced options for localness” because they will be capable of extending local coverage, local news content gathering, the media platforms that carry local news, and the availability of news footage.214 It is unclear exactly how they will do this, but a report by Ofcom mentions “economies of scale” and “scope for news consortia to develop lower cost models of news provision through greater efficiencies or new working practices.”215 Although this will depend on the commercial arrangements that consortia members agree on, the report mentions sharing assets like property, studios, satellite trucks, or even staff and asset management systems.216
210
The bill initially stipulated that Ofcom gain a new function and be able to appoint providers of regional and local news directly. This aspect was amended and cut in the House of Commons Committee stage. http://www.culture.gov.uk/what_we_do/broadcasting/6549.aspx 211 Ch 5, Digital Britain, 22. 212 Local and Regional Media in the UK, Ofcom Discussion Document, 22 September 2009, 78. Available online at http://www.ofcom.org.uk/research/tv/reports/lrmuk/ 213 Channel 3 is estimated to enter into deficit by 2011 if it continues its current level of programming with its current business model. 214 http://www.ofcom.org.uk/research/tv/reports/lrmuk/Salford_local_media.pdf 215 Local and Regional Media in the UK, 98. 216 Ibid. 89
The system will be piloted in 2010 in Scotland, Wales, and Tyne Tees/Borders. These three IFNC pilots will entirely replace regional Channel 3 news programming in these “nations” and are expected to cost £40 million over two years. The pilot process will be a way to work out the remaining details of the program (which are many).
The pilots are also a way of projecting the future costs of the program. So far the official line is, “The costs of delivering news through consortia would depend on the level of news provision desired.”217 However, because Channel 3 spent £68 million on Regional News in 2010 and a projected £72 million in 2012, those figures are being used as estimates for the IFNC model.218 So far this subsidy will be entirely paid for with public funds; the UK government and Ofcom are still deciding whether IFNCs will be permitted advertising or other revenue opportunities as supplementary income.219 Funding decisions should be settled following the pilot stage, but at least one Ofcom report concluded that “external funding is required.”220 The report also noted that using the license fee surplus from the BBC is the government’s preferred option of supplementary funding221 and that, alternatively, “levies have been suggested,” but there is “stakeholder resistance.”222 By Rob Grabow and Cara Haberman [email protected], [email protected]
217 218
Ibid., 90. Ibid., 78. 219 Ch 5, Digital Britain, 22 220 http://www.ofcom.org.uk/research/tv/reports/lrmuk/Salford_local_media.pdf 221 http://www.guardian.co.uk/technology/2009/jun/16/digital-britain-bbc-licence-fee 222 http://www.ofcom.org.uk/research/tv/reports/lrmuk/Salford_local_media.pdf 90
A Case for Non-public Advertising Subsidies in Bhutan
Introduction Approximately 70 percent of media revenue in Bhutan comes from public advertising.223 This financial dependency puts the government and the domestic media in a precarious position. On the one hand, the government, in accordance with its constitutional mandate to do so and its fidelity to the Gross National Happiness pillar of good governance, wants to promote free and independent media. On the other hand the press is financially dependent on the government it is expected to hold accountable, which may compromise its independence.
While the conflict of interest is apparent, Bhutan gives no hint that it intends to use public advertising to censor or influence media content to base ends. In fact, the opposite appears to be true; the ministry of information wants to incentivize the media to support GNH values, rewarding this behavior with targeted public advertising placements. This is a laudable target, but one which could undermine the press’s independence and duly compromise Bhutan’s fourth pillar of good governance.
Recent histories of numerous countries, provinces, and municipalities from around the world show that when public advertising is conditionally tied to content—“good” or “bad”— particularly in environments in which the media are heavily reliant on public advertising for viability, abuse and corruption can become inveterate. The structures that mandate socially “good” content generally also permit the “bad.”224
Guy Berger the proprietor of Grocotts Mail, a South African paper, knows these risks well. In 2007, he saw his paper’s well of advertising dry up because the Grahamstown municipality “disapproved of the paper’s coverage.”225 While Berger eventually won his appeal, after throwing “constitution and other legal arguments,”226 at his would-be censors, his example is
223 224
Kinley Dorji Email http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 225 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 226 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 91
illustrative of the dangers of public advertising—that it often ends up being used as both a carrot to reward coverage that supports the government and as a stick punish media that do not.
“While the media are not entitled to receive any advertising at all, what they are entitled to is not to be descriminated against,” says Berger.227 More blunt in his language, Robert Bousquet, senior advisor with Canada’s Communication Policy says, “Governments should not use advertising to subsidize the press,” a sentiment echoed by Darian Pavli, an attorney with the Justice Initiative at the Open Society during an interview on November 3, 2010.228, 229
Instead of being used as a subsidy tool, public advertising’s circumscribed role in Bhutan should be to “inform the public in an open, fair, and cost-effective way about important government policies, programs, and services (and how to benefit from them),” in essence allowing the governement to communicate with citizens and citizens to communicate and give feedback to the government while remaining “responsive to the diverse information needs of the public.”230
Per the media’s inability to be extant without public succor, this decision is only part of a solution. Despite Bhutan’s commendable willingness to lend financial assistance, to eschew glaring conflicts of interest, and to ensure that media are and appear to be independent, the government should consider a subsidy policy specifically intended to aid the media as an alternative to one that uses public advertising to do so. Thoroughly vetted policies in Sweden, Canada, and the United Kingdom provide alternatives for newspaper production and distribution subsidies, radio and television support for local content, and sundry grants for culturally important programming, which can be distributed in a equitable manner with sufficient devolution of authority, oversight, and well-thought-out guidelines to diminish risks of abuse.
Some implied concerns about news subsidies are that they further centralize government authority and that media would be less likely to criticize a government that subsidizes their expense. However, if carefully structured, that propensity can be dramatically diminished, as one
227 228
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf Interview with Robert Bousquet, Rob Grabow. 11/2/2010. 229 Interview with Darian Pavli, Rob Grabow and Barbara Magid. 11/3/2010. 230 http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-2008-2009-eng.pdf 92
survey of Swedish newspaper editors found: newspaper editors were still willing to criticize “the government in the papers, even though they are supported by subsidies.”231
If recent history is considered, the risks of a subsidy model that use public advertising (as opposed to a more specialized policy) to steer monies or influence content seem to be particularly prone to abuse. While “the specifics of how soft censorship is applied vary from region to region and even from country to country within a region,” soft-censorship through government advertising is uncomfortably common in several parts of the world, including: Eastern Europe and South and East Asia, and is especially problematic in Latin American and Africa.232
Misuse of Government Advertising
Argentina A report published in 2008 by the Argentine Association for Civil Rights and the Open Society Justice Initiative found that the “national government regularly abuses its advertising powers, including through excessive allocations to political favorites and denial of advertising in retaliation for critical coverage. Such abuses are even more marked at the local level, where media are, as a rule, more dependent on provincial and municipal advertising.”233 This last point is particularly pertinent to Bhutan where roughly 70 percent of the media budget currently comes from government advertising.234 A recent Supreme Court ruling declared such actions unconstitutional, stating in its ruling, “Government discrimination in the placement of advertising is an act of indirect coercion that is contrary to freedom of speech,” later adding, “The Government may not manipulate advertising by giving it to or taking it away from media outlets on the basis of discriminatory criteria.”
http://www.eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailmini.jsp?_nfpb=true&_&ERICExtSe arch_SearchValue_0=EJ294688&ERICExtSearch_SearchType_0=no&accno=EJ294688 232 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 233 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 234 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 93
231
Despite the ruling, identifying soft censorship is problematic. This is why Catalina Botero, special rapporteur for freedom of expression for the Organization of American States, said it was her view that government advertising is inappropriate as a subsidy, adding that, in deciding who receives funds for public advertising, “the determining criterion should be reaching the audience that it is supposed to reach.”235
Colombia In rural regions of Colombia, where media are almost completely reliant on public advertising to stay in business, “the government splits up its advertising budgets among radio journalists without regard to their stations’ audience reach.” In return, not surprisingly, “the radio stations then treat the government with deference.”236 The consequence as Jaime Abello, the executive director of the Foundation for New Iberian-American Journalism, pointed out was that “The importance of the message was secondary to rewarding reporters who would provide favorable coverage.” 237 Mexico Mexico’s story is similar in that “the withdrawal of government advertising on the local and national levels has become a common tactic for discouraging criticism of the government.”238 In one instance, the governor of Puebla, Mario Marin Torres, denied public contracts to three online papers, which had been “critical of his administration and reported on his alleged connection with a businessman implicated in a pedophile ring.”239 The backlash from the editors at one of the papers, e-consulta, which had been denied advertising, was severe. “It’s absurdly unfair; they provide contracts to media outlets that have no ratings and that cannot provide valid circulation numbers, yet they cut us off because we are critical,” Rodolfo Ruiz Rodríguez, the paper’s director told CEPET.240
235 236
http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 237 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 238 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 239 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 240 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 94
Bermuda One of the risks when public advertising is used as subsidy is that it becomes difficult to determine whether or not advertising is being withdrawn for a legitimate reason or simply because a medium is critical of the government. Often it’s the latter speciously cloaked in the former. Such appears to be the case in Bermuda. “In March 2008, the government of Bermuda cut its advertising budget of about $800,000 for the Royal Gazette.”241 The government, which didn’t “explain why it believed electronic media would be more effective in reaching the people,” cited a strategic shift away from print in favor of online advertising in reaching this decision. Government advertising, however, continues in the island’s other privately owned newspaper despite its lower circulation.”242 Alarmed by this action and doubtful of the government’s rationale, editors at the Royal Gazette cried foul, arguing that the cuts were in retaliation to the paper’s campaign that “supported access to public information legislation in Bermuda.”243 Reporters Without Borders, the Inter-American Press Association, the World Association of Newspapers, and the International Press Institute all expressed concerns in letters to Bermuda’s premier.244
Pakistan In 2006, the Pakistani government withdrew advertising “in the Dawn Group, one of Pakistan’s leading English-language media companies, after Dawn refused a government request for a news blackout of military action.”245
Nepal Following a declared state of emergency, Nepal’s Information minister confirmed a monarchical decree to “stop payment for advertising to private media.”246 Information Minister Tanka Dhakal added to this directive, saying the government was “seriously thinking of giving incentives to those media working for the nation and the crown, so we have stopped giving ads to the private media temporarily.” The government then started to steer advertising to media outlets deemed
241 242
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“responsible.” Nepal’s case underscores the risk of tying eligibility for government advertising to compliance with state directives, even noble ones such as GNH.
Botswana The Media Institute of Southern Africa sees a “growing tendency to use the placement of advertising as inducement to influence editorial decisions,” adding, “Freedom of expression cannot be held at ransom to economic factors; otherwise, the right to information, as enshrined in various international and regional conventions and protocols, would have no meaning.” 247
Moldova In Moldova, a report by the Independent Journalism Center found that “the print-run does not seem to be a criterion that public agencies take into account when they decide to post advertising in newspapers.”248 Related, that same study found that “advertising paid for from public funds is the most visible form of funding of the media by the state and is an important economic level used to influence them.”249 That sort of indirect censoring underscores the risks Bhutan faces in using public advertising funds to subsidize the media.
Conclusion Bhutan, which wants to promote GNH and build a knowledge-based society, needs to subsidize the press and must advertise things like tenders, health advisories, and large campaigns. In using public advertising to conditionally (or unconditionally) subsidize the press, a seemingly praiseworthy marriage of interests—between Bhutan’s broad goal of promoting GNH values and a more circumscribed objective of subsidizing the press through government advertising—may sound a death knell to the credibility of the country’s press. Bhutan also risks the appearance of not fully respecting its fourth pillar of good governance and may appear to be anti-freedom of speech.250
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http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf 249 http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf
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Because of the media’s reliance on public advertising to stay operational, if public advertising is used as a subsidy, and more disconcertingly as a subsidy for GNH-promoting content, in addition to the risks of abuse such a policy would invite, it creates a more simple collision of interests. What if the newspaper that has the ability to reach the audience at risk for a small pox outbreak is deemed by the government not to promote GNH values? Would the government be barred from advertising in that paper? Irrespective of the answer, the conflict becomes messy. There is an important place for GNH in public advertising, e.g., the government running a GNHpromotional campaign—it just should not be used to manacle or direct the content of a free press. Roberto Sabo, executive director of the Association for Civil Rights in Argentina summed up this idea well with an example: “If a state government advertises to attract tourists, it should not subsidize local media with that advertising; rather it should place those ads in media whose audiences are located elsewhere.” 251 By Rob Grabow [email protected]
For More Information
A large body of literature exists on the subject of public advertising. The following section highlights some key references identified throughout the team’s research:
Public Advertising Policies
• Australia’s Current Advertising Guidelines: “Guidelines on Information and Advertising Campaigns by Australian Government Departments and Agencies” http://www.finance.gov.au/advertising/docs/Guidelines-on-Information-and-AdvertisingCampaigns-by-Australian-Government-Departments-and-Agencies-March-2010.pdf
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www.fopea.org/content/download/1301/.../Soft%20censorship%20report.pdf, 7. 97
•
Canada’s Current Advertising Guidelines: http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=12316§ion=text
•
“Engaging Through Social Media,” Central Office of Information (COI), November 2010.
•
Industrial Promotion Policies—Central Government Advertisement Policy (with effect from 1 June 2006) http://advertising.indiabizclub.com/info/government_policies
Misuses of Public Advertising
• Canada’s Sponsorship Scandal http://www.cbc.ca/news/background/groupaction/ • CIMA’s Censorship Report http://www.radiopeaceafrica.org/assets/texts/pdf/cima-soft_censorship-report.pdf • Rafael Di Tella. “Government Advertising and Media Coverage of Corruption Scandals,” Ignacio Franceschelli, NBER Working Paper. October 2009. http://www.nber.org/papers/w15402.pdf • India’s Advertising Bloopers o Priscilla Jebaraj. “African Jumbo in Incredible India Ad,” http://www.thehindu.com/news/national/article799389.ece o Press Trust of India, “3 Crores in 2 Months for Rajiv Gandhi Ads,” NDTV, Friday January 29, 2010, New Delhi. • Sally Young. “Not Biting the Hand that Feeds: Theories for understanding government advertising in Australia” • Sally Young. “Political advertising: hey big spender!” in M. Simms and J. Warhurst, editors, Mortgage Nation: The 2004 Federal Election, Perth: API Network. 2005. • Sally Young. “Reform and Resistance: The Regulation of Government Advertising in Australia.” Australasian Political Studies Association Annual Conference. 25-27 September 2006, University of Newcastle, City Hall, Newcastle. • Sally Young. “The Regulation of Government Advertising in Australia: The Politicisation of a Public Policy Issue.” Australian Journal of Public Affairs. 2007.
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South Africa Abuses http://www.journalism.co.za/index.php?option=com_content&Itemid=100009&catid=16 5&id=1067&view=article http://nml.ru.ac.za/blog/guy-berger/2008/10/24/resources-about-government-advertisingboycotts-private-media.html
Annual Reports
• Australia’s 2009–10 Campaign Advertising Annual Report “Campaign Advertising by Australian Government Departments and Agencies: Full Year Report 2009–10” • Canada’s 2008–2009 Public Advertising Annual Report http://www.tpsgc-pwgsc.gc.ca/pub-adv/rapports-reports/documents/rapport-report-20082009-eng.pdf • India’s 2009–2010 Annual Report for the Directorate of Advertising and Visual Publicity http://www.davp.nic.in/aenglish0910.pdf • South Africa’s Budget http://www.treasury.gov.za/documents/national%20budget/2008/ene/6%20gcis.pdf
Evaluations of Policy
• Allan Hawke. “Independent Review of Government Advertising Arrangements,” February 26, 2010. http://www.finance.gov.au/advertising/docs/Independent-Review-of-GovernmentAdvertising-Arrangements.pdf • “Facts and Figures,” Office of Communications (Ofcom), November 2010.
Tenders
• Tenders http://www.gcis.gov.za/aboutus/procurement/index.html
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Alternative Media Subsidy Programs • Canada’s Local Programming Improvement Fund
http://www.crtc.gc.ca/multites/mtwdk.exe?k=glossaryglossaire&l=60&w=42&n=1&s=5&t=2 • Canadian Program Certification http://www.crtc.gc.ca/eng/info_sht/tv11.htm • Canada’s Public Benefit’s Test http://www.crtc.gc.ca/eng/archive/1993/pb93-68.htm • “Efficient Servants of Pluralism or Marginalized Media Policy Tools: The Case of Swedish Press Subsidies” http://jci.sagepub.com/content/33/4/376.full.pdf+html • “How Were the United Kingdom’s License Fees Spent in 2009–10” http://www.bbc.co.uk/aboutthebbc/licencefee/ • “Newspaper Subsidies in Sweden Pose No Dangers, Its Editors Feel.” http://www.eric.ed.gov/ERICWebPortal/custom/portlets/recordDetails/detailmini.jsp?_nf pb=true&_&ERICExtSearch_SearchValue_0=EJ294688&ERICExtSearch_SearchType_ 0=no&accno=EJ294688 • “Press Subsidies and Local News: The Swedish Case.” http://reutersinstitute.politics.ox.ac.uk/fileadmin/documents/Publications/Press_Subsidies _Local_News_the_Swedish_Case_Final.pdf • United Kingdom’s Television Licensing Requirements http://www.tvlicensing.co.uk/easy-read/why-you-need-a-tv-licence-ea25
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doc_155711042.pdf