Note 8: Communications Activity
1. The general principle governing communications work during the election period is to do everything possible to avoid competition with Parliamentary candidates for the attention of the public. In addition, special care must be taken as information produced with complete impartiality and accepted as objective at other times may attract criticism during the election period.
2. References in this note to Communications Officers apply equally to all officials involved in similar work and any communication activity. It is incumbent on all to adhere to the principles as well as the provisions of the Civil Service Code. The principles extend to the use of the Internet and Intranet (see paragraph 8 below).
Regular Scottish Government Communication activity
3. During an election campaign the Government retains its responsibility to govern and Ministers remain in charge of their portfolios. Only essential business must be carried on and supported by Communications as appropriate and in a proportionate way. See Note 1 for general guidance on this point in relation to COVID-19 activity in particular.
4. Scottish Government Communications staff may continue to discharge their normal function only to the extent of providing factual explanation of current Government policy, statements and decisions. They must be careful not to become involved in a partisan way in election issues. Arrangements for articles, interviews, etc. by Ministers during the election period will normally be made by the political network - except where they relate to essential official business.
5. The Government's normal daily news service will therefore effectively be suspended, including provision of the regular briefings for Parliamentary journalists during the election period. Essential business which support Public Information dissemination concerning COVID-19 will be permitted, but it should at all times adhere to the principles set out in this guidance.
6. During the election period, access to briefing will be restricted to permanent civil servants who will respond to information requests in line with the principles set out in Note 2. Any updating of briefing lines should be confined to matters of fact and explanations of existing Government policy. Briefing may be an appropriate resource for Private Offices to use when providing factual information to Ministers in line with Note 1. Ministerial activity should be reviewed by Private Offices and Communications staff when the election period begins and confined to permitted Government announcements and official engagements during the campaign period and not beyond.
7. Guidance for Scottish Government Communications staff is as follows:
News media relations
a) In response to questions, communications officers should, where possible, provide factual information by reference to published material, including that on websites. Specific requests for unpublished material should be handled in accordance with the Freedom of Information (Scotland) Act 2002.
b) There is no objection to issuing routine factual news releases covering subjects, such as employment statistics, which are issued on a monthly or regular basis. Ministerial comment should, however, normally be issued through the Minister's political party. Equally, reports from public bodies and independent committees that the Government is required to publish can be summarised and drawn to the attention of the media.
c) Communications officers should not handle statements that refer to the Government's future intentions, unless referring to previous, publicly recorded statements. Instead, these can be made by the Minister concerned in a political speech to be handled by the political party.
d) Where a Minister is involved in activity associated with essential Government business, such as attendance at an event, the relevant Communications team should provide support, limited to the provision of factual information.
e) The Communications team should not handle statements or comments referring to the policies, commitments or perceived intentions of the opposition parties.
f) During the election period, arrangements for newspaper articles, interviews and broadcasts by Ministers, including digital and social media content, will normally be made through the political network. Care should be taken by communications staff in arranging and accompanying/supporting any press interviews for Ministers and Government Clinicians, as appropriate, during this period because of the possibility that such interviews would have a strong political content, and the distinction between political and Ministerial publicity will be under very close scrutiny during this period. They should not arrange publicity through official channels unless Communications staff are satisfied there is a need to do so for reasons of essential business and that the Minister is speaking in a Government, not party, capacity.
g) If a Minister proposes to make an important Ministerial statement during the election period, this should be discussed with the Director of Communications and Ministerial Support, the Head of News, and the Cabinet Secretariat. Equally, if a Minister intends to hold a news conference to make clear the Government's policies on a particular subject of immediate importance, guidance should be sought from the Head of News and from Cabinet Secretariat, and the Government should provide facilities where appropriate.
a) New marketing campaigns will not be launched in this period. Running of above the line marketing activity will cease, e.g. advertising. This covers both domestic and international activity. However, some essential marketing and advertising (for example COVID-19 and public health issues, civil emergencies, specialist recruitment) may be permitted in consultation with the Scottish Government's Director of Communications and Ministerial Support and the Head of Marketing. This will be considered on a case-by-case basis.
b) Where such advertising is commissioned by a UK Government department, the UK department concerned must first consult the Head of the Government Communications Service and the Scottish Government's Deputy Director for Marketing, Insight, Brand Scotland & Internal Communications, Pauline Aylesbury. Marketing information websites associated with public information or social marketing subjects will continue to be live and updated with appropriate changes to continue to be factually correct. No new content will be created or promoted.
c) Websites that support marketing campaigns by providing the public with information, may continue to stay live. New content can only be added if it is clearly not politically linked and also meets the same exemptions as outlined above (i.e. is related to public health issues, civil emergencies or specialist recruitment).
d) Marketing campaign related social media activity may continue to engage with the public where the content is not new or politically linked, and where no above-the-line advertising spend is being used. This includes responding to queries received (for example to communicate public information messages to audiences).
e) PR Media relations in support of campaigns will cease during the election period.
f) Printed material should not normally be given any fresh distribution in Scotland during the election period, in order to avoid any competition with the flow of election material. The effect on distribution of posters and leaflets to the public is as follows:
i. Posters. The normal display of existing posters on official premises may continue, but efforts should not be made to seek display elsewhere. Specific requests by, stakeholders and partners, for particular posters will be met in the ordinary way.
ii. Leaflets. Small numbers of copies of leaflets may be issued on request to members of the public and Parliamentary candidates. Bulk supplies should not be issued to any individuals or organisations without approval from the Deputy Director for Marketing, Insight, Brand Scotland & Internal Communications.
g) Official 'filler' films and radio tapes transmitted in intervals or public service periods of TV and radio programmes may be limited, in consultation with the BBC and Ofcom.
h) Films, videos and photographs from Scottish Government libraries or sources remain available to be shared online but no new images should be uploaded. The ability to share images does not imply Scottish Government endorsement of the views or comments of an individual, party, or group.
i) Exhibitions which form part of a privately sponsored exhibition should not be withdrawn, but self‐contained official exhibitions or privately sponsored ones advocating a politically contentious policy should not be kept open or opened during the election period.
j) Window Displays. Normal display of factual information on official premises may continue, but promotional displays should be withdrawn or withheld.
k) Research and evaluation. Fieldwork involving interviews with the public or sections of it will be postponed or abandoned, although regular, continuous and ongoing statistical surveys may continue.
The Scottish Government Website
a) The general principles on information activities during Parliamentary elections will apply to the Government's main corporate website: www.gov.scot and any other websites operated by Government, including marketing campaign websites.
b) Other official websites operated by Government agencies and national devolved public bodies should also comply with these principles. A list of the relevant public bodies can be found on the Scottish Government website.
c) The Government's normal online news service on www.gov.scot will effectively be suspended. No Ministerial videos or new social media content will be recorded or broadcast. Given the exceptional circumstances and the response to COVID-19, careful consideration should be given to the means of dissemination of any public information in relation to COVID-19, with each instance considered on its merits. The only items to be posted in the news section will be non‐controversial, factual or routine, as defined above, including statistics notices, pre‐planned publications, and public information in relation to COVID-19.
d) All material published on www.gov.scot prior to the election period, including video, Ministerial biographies, and policy information, will be regarded as part of the historical record and will remain accessible to the public. No significant additions or improvements will be made to that information.
e) All material published prior to the election period on the different websites will also continue to be publicly available. No significant additions or improvements will be made.
a) During the election period, Government pages on most social media sites that aim to engage or inform should not be added to, expanded or improved, and nor should responses be made to comments posted. The reasons for this should be made clear on the relevant sites/pages, with links made to the Scottish Government's primary channels for the purpose of promoting essential COVID-19 public health information only with each instance considered on its merits.
b) Given the exceptional circumstances and the response to COVID-19, the main Scottish Government Twitter, Facebook, Instagram and LinkedIn channels may continue to post essential public health messages, where it supports related news or marketing activity in this area, in accordance with the above definitions.
c) Where Government‐backed social media sites promoting Scotland are aimed principally at international audiences (for example, www.scotland.org) engagement and provision of information can continue but should avoid political reference and controversy.
d) Civil servants' participation in a professional capacity in social networks (for example, Facebook, Twitter and Instagram) as well as in forums, online communities and other public online discussions should be limited during the election period to:
- Commenting on operational matters relating to services such as notifying users of technical problems with a website or digital service; and
- Responding to factual queries by signposting existing content. Any exceptions to this guidance should be referred to the Head of News, who will consider individual cases as appropriate.
e) As set out in Scottish Government Social Media guidance, civil servants should continue to use personal accounts with responsibility and care in line with the Civil Service Code. In particular, as the guidance sets out, civil servants must also not take part in any political or other public activity which compromises, or could be seen to compromise, our impartial service to the Government of the day. Liking, sharing and commenting on content can all be interpreted as expressing an opinion. In addition, the caveat 'all views are my own', or 'retweet does not equal endorsement' does not make civil servants immune to being associated with any content engaged with on social media.
Blogs and Video
a) There should be no new public facing or Ministerial blogs during the election period. Civil servants may continue to respond to comments on existing blog posts, provide routine and factual responses to queries, and moderate for inappropriate comments.
b) Ministerial blogs, videos and social network profiles should not be updated for the duration of the election period.
Journalists from overseas
8. Any journalist from overseas - press, television or radio - who is not an official visitor and who may ask for assistance on political matters should be given the addresses of the central or local party offices.
Facilities for Information Material for Overseas Use
9. The permission of the political parties must be sought for any photography, filming and sound recording in particular constituencies, for use overseas.
10. For further information, please contact the Director of Communications and Ministerial Support, and your query will be directed to the relevant colleague who will be able to advise.
11. Scottish Government Agencies and national devolved public bodies should consult their own Head of Communications for advice in relation to the application of the Communications guidance in their own organisation in the first instance.