This blog is based on a letter I have sent to Malcolm Burr, Chief Executive of Comhairle nan Eilean Siar, and to local press and media. In it I am asking Mr Burr to suspend the current public consultation, radically redefine the communications strategy and then return to public consultation.
The Comhairle’s public consultation, as it stands, can be accessed here:
Dear Mr. Malcolm Burr,
re: Comhairle Communications Strategy and Consultation
I would like to take this opportunity to congratulate the Comhairle on its decision to consult with the public on its communications strategy – congratulations!
But I must also take this opportunity to raise very serious concerns about the limited scope of the consultation, and to seek an immediate suspension of the current process in favour of a rethink and a relaunch that will give the public – the council tax payers and service users of the Comhairle – a real opportunity to comment on all aspects of this most important of Comhairle policies, and that includes the most fundamental aims of the policy.
The key missing elements in this strategy, and the public consultation, are, firstly, the public are not being asked to define the nature and content of Comhairle communications, members of the public are not being asked what information they actually want to have, how they receive it and to state why they want it. Click boxes and spaces for comment do not amount to a full consultation.
Secondly, issues of openness, accessibility and freedom of information are fundamental to local authority communications. These are not mentioned, and comment is not requested.
Too much of the current aims and benefits of the communication strategy, as presented on line and in this consultation, is focussed on ill-defined and unmeasured values, and too much on issues surrounding how the Comhairle can manage public perceptions of itself as an organisation.
Why should the public care?
The issue of communications has rarely been more important for the Comhairle.
At a time when the Comhairle is facing one of its biggest challenges in many years; with very serious pressures to which cash is not available as the answer, and at a time in which the Comhairle is having to make very painful decisions about cutting public services, the relationship between the Comhairle and the public is of profound importance – and communications sits at the heart of that relationship.
When so much is at stake and in a time of virtual austerity in Comhairle finances, the public, the tax payers, the service users, those interested in democracy locally, need information, and we need to be given the means of having confidence in the fact that the information we are receiving, and being offered access to, is as full and open as it can be.
I will happily urge local taxpayers and service users to fully engage with the consultation when and if it has been redefined, but as it stands, I fear that participation in the current consultation will only strengthen the negative impact of the current communications strategy, and will do nothing to increase openness and freedom of information.
In more detail, and some examples of what is wrong and what is missing…
The Comhairle’s current consultation on its communications strategy begins with an introduction (a kind of set of aims and benefits) that is not itself the subject of the consultation. It is a leading statement full of unmeasured, positive but subjective adjectives, and which, on the surface, as a consequence of the manner of presentation, seem obvious and consensual, but they are not.
What, for example, does the opening sentence of the Comhairle statement – ‘Good communication should be essential for every organisation.’ – actually mean? This is a value judgement not a statement of policy or fact, as ‘Good communication’ is not defined.
Who determines what is ‘good’ communication and how do they determine it? Is this value (‘good’) judged according to whether or not Comhairle members are re-elected? Or is ‘good’ achieved when public perceptions of the Comhairle are always positive? Is ‘good’ attained when public confidence is maintained by withholding or ‘spinning’ key information?
The risk for the Comhairle, based on the example above, is that the opening blurb of this ‘consultation’ is perceived as being designed to set and control the parameters of the consultation, and it is itself evidence that the communications strategy is in urgent need of serious review.
A reasonable response to the Comhairle’s introductory blurb, and hence the consultation as a whole, would be that the organisation is wishing to limit and contain the scope of public engagement and comment on its communications policy, and to maintain, at best, a status quo whilst appearing to be engaging with the public.
Controlling the flow and accessibility of information is a means of controlling and managing public perception. When we as council tax payers are being asked to understand the predicament that the Comhairle faces, we need confidence that we are getting the information we want, and in an accessible manner, to be able to know how decisions about information are made and who makes them and why.
Public perception is, it seems, a more valuable commodity to politicians than accessibility of information, and that is what is wrong with the current communications strategy, and this consultation.
There is too great a confusion between the communications strategy that enables an information supply from the Comhairle as a statutory organisation, concerning public knowledge and awareness of that organisation, its activities and efficiencies, and the communications strategy of the Comhairle as a political entity, and the needs of the elected councillors. See below.
We, the tax paying public, must at the same time reassure our elected politicians that deciding on a commitment to increased openness is not like turkeys voting for Christmas. Openness is fundamental to resolving the current crisis affecting the Comhairle, and the current crisis affecting public confidence in the Comhairle.
The opening statement referred to above is also mired in lazy corporate speak – who or what, for example, is a stakeholder? There are many other similar examples of corporate speak throughout the document and questionnaire which I will happily identify if necessary.
Some of this subjective and cliche-ridden waffle might be intentional, I fear that most of it stems from the same muddled sources that gave us the communications debacle that has surrounded the issue, for example, of charging some parents for their children’s use of the school buses.
An increase in public fear and confusion is not surely an aim of the Comhairle’s existing communications policy, but it has surely been an outcome. How did this happen? What can the Comhairle learn from such a mess? Does the Comhairle want to learn from such a mess? If so, halt this flawed consultation now.
Another example of what is wrong with this strategy and consultation, is that the opening blurb also says that:
‘The benefits of implementing the strategy are intended to be: [...] The Comhairle’s achievements will be better known by the public and other stakeholders;’
Really? Who defines what is an achievement and what is the measure? The policy/strategy should at least tell us this so that we can have trust in the independence of the determination. Is democracy not better served by telling us in equal measure the achievements and failures?
Is it the job of the Comhairle to engage solely in positive, vanity communications?
This so-called ‘benefit’ is, without answers to these questions, and more seriously a deeply undemocratic aim and one that is completely at odds with any policy about openness. All it will achieve is to further undermine participation in democracy and trust in the Comhairle, with a perception that the Comhairle’s communications policy is largely defined to support positive public perceptions of the decision makers.
I assert that this so-called benefit (to who? and who decided that this is a benefit?) needs to be removed, the thinking behind it explored, and a new policy of neutral communication based on openness and accessibility of information implemented as soon as possible. Otherwise, this so-called benefit is totally at odds with the statement, also in the opening blurb:
‘Good, effective communication also helps strengthen democracy and allows for participation with and by the Comhairle’s key stakeholders including the public and the Comhairle’s employees.’
If ‘good’ communication is measured by the flow of communications about ‘achievements’, and the public know this but do not control the definition of ‘achievement’, democracy is very seriously undermined.
As stated at the opening of this letter, nowhere in this consultation is the public asked to comment on fundamental questions about the information it / they wish to receive from and about the Comhairle. We are asked about the Comhairle’s use of ‘e-media’ and to comment on our favoured news sources. Fair enough. But that is tinkering at the edges of a policy when comment on the real issues is being very much controlled and/or denied.
Councillors very freely highlight what they define as public apathy. But in this consultation we are not asked to comment on openness and freedom of information. We are not asked if the format of public meetings on Comhairle cuts, for example, is the way in which we to be consulted. Alternatives are not suggested to you to help us decide what is the best way forward.
A lack of confidence in the openness of the Comhairle, and the on-going decline in public trust of the Comhairle, create apathy. But this can be addressed through the communications strategy. As it stands this will not be achieved.
The public are not asked in this consultation if Comhairle employees should be given greater freedom to comment in public debates about Comhairle decisions without fear of disciplinary action. Why not?
So, I close with an alternative vision for debate. I welcome comment of all kinds. Here are 8 proposals, I’m sure that there are many more, please let me know.
1. The Comhairle’s communications strategy is one of the major means by which the Comhairle defines its relationship to the public, other organisations and service users. It should be the embodiment and guarantee of a new aim to become the most open and accessible local authority in Scotland – If not, why not? Measurement of openness and accessibility are to be defined, utilised and published annually so that the public can determine whether or not this commitment is being fully implemented.
2. The Comhairle fulfils its statutory requirements with regard to confidentiality to the letter; and fulfils statutory requirements with regard to public announcements – yes of course.
3. The Comhairle commits to reducing the quantity of information that it defines as private or confidential. This to be measured against a baseline figure. Even if this is currently at a minimum, proof helps to boost public confidence. Very clear guidelines for officers and elected members are to be published so that the public can know why information might be with-held, and how the Comhairle interprets the law on these matters.
4. The Comhairle commits to decrease the quantity of meetings that are held in closed session. This can be measured against a baseline figure, proof helps to boost public confidence.
5. The Comhairle aims to make all agendas, minutes and other documents available to the public as quickly as possible, as defined by ensuring that the public and the media have the maximum time available to comment.
6. The Comhairle strengthens local democracy by using its communications budget to support plurality of ownership and sustainability of local media outlets, with a bias toward expenditure on community owned media platforms.
7. The Comhairle engages with the public and other organisations via social media, and works to simplify and clarify its language in all its communications.
8. Comhairle staff are encouraged to disclose wrong-doing, illegal activity or concerns about such things, and are encouraged, as far as the law allows and while respecting statutory requirements for confidentiality, to participate in public debate about the future of the services in which they work, and about which they care, and to do so without fear of disciplinary action.
To close, I repeat my call for the current consultation to be suspended, redefined and relaunched.