A: Providing robust advice

Last updated: 05 Feb 2016

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Problems exposed

The program design and implementation of the HIP and the NBN were compromised by the APS failing to provide robust advice. Public servants did not draw sufficiently on external views and expertise,[68] and the partial evidence they did muster was unable to exert influence through its advice to ministers.[69] There was a failure to provide sufficiently frank and forthright advice to ministers on important elements of policy design and risk.[70] There was a significant gap between the inadequate levels of candour displayed in written advice and that reportedly conveyed in oral briefings. Public servants failed to keep detailed records of key decisions and how they were arrived at, nor did they put into writing concerns regarding design features of the program, despite testimony that this was raised orally with ministers.[71] The APS, Hanger concluded, "ought to reinvigorate its willingness to provide, in writing, advice that is as frank and robust as the advice it is willing to give verbally".[72]

Ministers themselves frequently bemoan the quality of the advice that they receive. There have been recurrent complaints over recent years from ministers about their departments' apparent lack of innovative ideas and inadequate standard of advice. This may not be the experience or perspective of most ministers, but it is a complaint that I have frequently heard. "Don't public servants have interesting ideas?", I am asked, usually accompanied by, "Why do they always tell me that things can't be done?". The answer, I hope, is that public servants do like to contribute to good public policy but need to be encouraged to present their views forthrightly on a confidential basis.

Providing advice to ministers has long ceased to be the exclusive domain of the public service. Ministers have access to a wider range of sources than ever before, including their party colleagues, political advisers, industry lobbyists, community advocates, policy think tanks and academia. They also hear from their constituents and individual citizens. This is a good thing: being able to draw on more information and multiple perspectives supports better decision-making. Public servants need to have the capacity to argue their case against alternative views.

Even in this contested environment, the APS remains in a position of strategic importance at the centre of government. Public servants are privy to ministerial decisions in a way that others are not. While outsiders may engage at different points in the policy process, the APS's involvement spans every stage—from bouncing around ideas, setting agendas, formulating policy and undertaking design to delivering, monitoring and evaluating a program's implementation. Continuous proximity to political power contributes to the unique role of public servants. They are privy to many (but not all) of the important conversations. But these advantages do not guarantee influence or relevance. For this, public servants—individually and collectively—must establish and maintain a reputation for reliably delivering the best-argued and most persuasive advice.

Problems addressed

Good advice should be responsive and timely. Responsiveness requires public servants to be sensitive to government priorities and alert to the intent and direction of policies. Advice and options should be based on an understanding of ministers' expectations, but also identify their unintended consequences and what alternative approaches might help a minister to deliver their goals more effectively. Responsive advice needs to be politically astute. It should recognise the choices and constraints ministers face and include options to address them. It is also proactive, vigilant for opportunities and anticipating problems. Good advice reflects an understanding that policy development often takes a long and circuitous path, progressively adapting to the unexpected twists and turns of political debate, discussion and circumstance. Over-responsiveness—where public servants hold back on giving critical advice in a display of undue deference to their ministers' views—can be fatal to good policy outcomes. When a minister says "jump", the response should not be "how high?". Nor should it be "no". A better question is "in what direction and for what purpose?" Advice that is contrary to ministers' expectations is justified where it is based on a solid grasp of the government's objectives and aimed at supporting their achievement in the best way possible. It must reflect departmental knowledge, obtained by thorough analysis and consultation, of the likely benefit of alternative approaches. It should be informed by a clear assessment of what can go wrong, because there is a good chance that it will.

Ministers frequently lament that advice from the public service is too slow. I have, on occasion, been the recipient of such remarks. The APS needs to prevent advice getting weighed down by process. hierarchical processes can play an important role in ensuring quality control and ethical standards. On the other hand, taken too far, the burden of bureaucratic process can create unnecessary delay and crush innovative ideas. papers sometimes go through a long succession of clearances by progressively more senior public servants before they are deemed ready for submission to a minister's office. The time lost is generally greater than the quality added. At the same time, it needs to be recognised that the preparation of good advice on complex issues can take time. This is more likely to be the case when governments are forging new policy directions, or are taking on functions with which they have had little experience. Uncharted waters take longer to navigate safely. In such circumstances, establishing demonstration projects may afford useful opportunities to learn by doing, rather than taking the risk of rolling out an untried program nationally.

Advice needs to be analytically rigorous, carefully balanced and unbiased in its assessment of evidence and options. This does not mean that it cannot be succinct. Conclusions should not be based upon—or worse, hidden within—voluminous appendices. A good public servant, from training and experience, should be sufficiently skilled to transform mountains of information into pinnacles of knowledge. Advice should be informed by the latest thinking and practice from around the world while being alert to the Australian context. Assumptions and uncertainties need to be made explicit.

The gathering of evidence should not stop once initial design decisions are made. It must be ongoing. Often interventions do not work as planned when they are implemented. Always the objective of early stages of program delivery should be to learn from the experience of doing. policy makers need to be attuned, responsive and ready to make the adjustments necessary to ensure that the best possible approach is put in place.

Mike Pezzullo

"Will this era be seen as one of… a close partnership between effective governments, high-calibre public servants working diligently together, and in partnership with civil society, industry partners and others?... These days departmental advice has to be highly influential and compelling. It has to be based… on strong evidence,… it has to be actionable, it has to be clear, and it has to relate to a clear public policy problem that's been defined, [and] we have to be completely conscious of the fact that our advice and our views are going to be impacted, and properly so, by contested views." (April 2014) [73]

Mike Pezzullo is the Secretary of the Department of Immigration and Border Protection

Advice should present a range of viable options and set out the potential unforeseen or unintended consequences of each, together with a delivery strategy and a risk management plan. Implementation must be properly considered throughout the policy cycle. Execution should be built into policy design rather than treated as an afterthought. Too often delivery matters are given tokenistic treatment, or settled without proper consultation with those who best understand the environment in which a policy will be delivered—often the public servants or community representatives on the frontline. Departments should ensure that ministers are briefed on strategic implementation issues, including on what options exist for implementation. In many instances that will require consideration of whether responsibility for delivery should be commissioned to providers outside of the APS. That will involve benchmarking and seeking alternative implementation mechanisms.

The public service has a role as a broker of information, perspectives and opinions. It must exercise the leadership of facilitation by consulting, arranging expert discussions, collaborating with business and not-for-profit organisations and 'crowdsourcing' a broad range of community views. Advice should be as open as possible to outside experience, with alternative ideas considered and assessed rather than ignored or peremptorily dismissed. Advice should harness knowledge from across government, other sectors and the public.

Consultation on large government programs and projects is often conceived far too narrowly. Good policy should harness the views of those likely to be impacted by the proposal. It needs to reflect a willingness to 'co-design' with those from other sectors who have on-the-ground experience of delivering major projects. As performance-based commissioning of public services becomes more commonplace, it will be increasingly important to ensure that program design and implementation are 'co-produced'. The possibility that there may be perceived conflicts of interest in involving community and business organisations that, in the future, may wish to tender to deliver government services, can be carefully managed.

Most importantly, good advice is frank and fearless. Good advice is not only responsive—but also responsible. It is forthright, honest and impartial. It should seek to be as objective as possible. This can mean telling ministers things that they may not wish to hear, but of which they need to be aware. Only then can we be assured that decisions are made in full knowledge of all the facts. Governments should act with eyes wide open. At that stage, even if the Secretary believes the government is acting unwisely, the answer is necessarily, 'Yes, Minister'. Only very occasionally will the response of a Secretary have to be firmly in the negative to ensure that their minister operates within the law, in accordance with parliamentary conventions or in line with established policy.

Michael Thawley AO

"I don't think there is any reason not to give direct advice to government. People outside the public service talk about frank and fearless advice as if there was a state of perpetual hostility, but that's not right. Public servants are interested in getting the right outcome and will do their best to persuade. Their interest is in the outcome, not a fight. If the government likes the advice it will choose it. If the government decides otherwise, it may reflect on our ability to provide a convincing argument or there may be other factors. It is not our business if there is a political reason." (April 2015)[74]

Michael Thawley is the Secretary of the department of the Prime Minister and Cabinet

Giving frank and fearless advice can be difficult. It can be complicated by the desire to preserve good working relationships with ministers. There can be pressure to be 'pragmatic' and act in a way that is expedient or convenient. The community's legitimate expectation that the APS serves the public interest with integrity requires more than this. It can require steely resolve. More generally, it requires innovative ideas and strategic thinking in order to present ministers with alternative options to meet their political objectives. Fearlessness should never become obstructionism.

Courage in giving ministers robust advice may be required regardless of whether it is delivered face-to-face or in a written briefing. Yet I have come firmly to the conclusion that fearless advice delivered orally is not the same as frankness written down. Oral advice can too easily give rise to misinterpretation or misunderstanding. It is more easily dismissed or forgotten. Committing advice to writing requires more coherent articulation of arguments and helps assure a shared understanding. For these reasons, policy advice can only be truly frank and fearless if it is supported by written argument. Ministers should demand that advice on the most challenging issues they face should be presented in written form. Ultimately, they should be able to expect that the advice received from their departments, whilst written in the interest of supporting them to achieve their objectives, is also forthright. Done well, this should enhance rather than erode an effective relationship between ministers and officials.

Responsibility for raising the bar on the quality of advice rests with all APS employees. however, some problems will only be overcome by the exercise of strong leadership at the highest levels. Ministers are entitled to expect that Secretaries will be proactive in ensuring that the preconditions for robust advice exist within their agencies, take responsibility for maintaining high standards, and be clear and decisive in responding where organisational performance falls short. For their part, ministers should create an environment which is conducive to encouraging and receiving the best possible public service advice.

A review's conclusions cannot depend on entreaty alone. A few modest initiatives might help to give effect to what most Secretaries know only too well already. First, Secretaries should be willing to be held accountable for the quality of advice provided by their departments. The question is how best to implement this. Ultimately, it is up to the Prime Minister of the day to decide how this should be achieved, in consultation with the Minister Assisting the Prime Minister for the Public Service, the Secretary of PM&C and the Australian Public Service Commissioner. Secretaries' annual performance discussions are one existing opportunity to discuss the quality of advice provided to ministers by their departments. Written briefing can also provide an opportunity to enable ministers to comment on the timeliness, relevance, and value of the advice they have received: some departments already include a summary box on each submitted paper to allow the minister to comment in this manner. Shortcomings need to be identified and addressed in a considered fashion.

Second, the minister-department relationship is strengthened when a Secretary has the good fortune of working to a minister who actively encourages frank advice. There may be value in capturing these sentiments in a Charter of Expectations which can serve as a guidepost for departments, ministers and their offices. The Charter could provide a standard against which performance can be assessed.

Third, in order to set a clear expectation about the requirement for significant advice to be in writing, the most effective mechanism would be for the Australian Public Service Commissioner to issue a binding Direction under the Public Service Act 1999.

Transparency of government processes and public access to government information is an important characteristic of participatory democracy in Australia. Making administrative decision-making more open to the public empowers citizens. It improves the quality and responsiveness of services. Similarly, increasing access to government data supports innovation by unlocking the economic and social value of information.[75] Freedom of information helps to assure transparency in the expenditure of public money and ensure accountability for the impact of decisions on individual citizens: indeed the community should be actively encouraged to use public information for all sorts of public purposes. Factual information collected at public expense should generally be available to the public to use as it pleases.

When it comes to advice based on opinion and judgement, and intended to inform deliberative decisions on policy, there needs to be a different approach.[76] Here the requirement for a relationship of trust between ministers and senior public servants means that arguments for confidentiality have much greater strength. It is far more difficult to be frank about politically sensitive policy matters when there is a real risk that one's advice will become publicly accessible. This is not to suggest that, where there are different views, the department's perspective will always be the correct one. Indeed my own experience suggests otherwise. Nonetheless, healthy differences of opinion between a minister and a Secretary will soon become a political issue if they are made public and can seriously damage the relationship between the two. Public servants, in the heat of a party political contest, face pressure to answer questions not on how they are administering a program but on whether departmental advice had supported it. If confidentiality is not assured, public servants will be tempted to temper their advice and ministers will prefer to receive advice only orally. This is a conclusion which is supported by an examination of the behaviours exhibited during development of the HIP.

John Fraser

"Freedom of information has made people extremely careful in the public service about what they put on paper, and that's sad. Freedom of information is not a bad thing in itself. But open policy debate means people have got to be candid. And at the moment a lot of it is done orally, which is a pity. It's a pity for history …. And writing something down is a great discipline." (May 2015)[77]

John Fraser is the Secretary to the Treasury

Whilst openness and transparency are fundamentally important for good government, governments must be allowed a measure of confidentiality in the policy-making process. Not to do so burdens ministers and their advisers in a way that other decision-makers are not. The executives and board members of both for-profit and not-for-profit organisations rely on confidential discussions, and a CEO is not generally required to disclose details of the board's deliberations. Nor is there an expectation that the courts will circulate draft opinions or records of discussions held on the way to presenting a judgement. Indeed this would be seen as inimical to good process.

The introduction of Australia's Freedom of Information (FOI) Act in 1982 (and comparable legislation in other jurisdictions) created a legally enforceable right of access to government documents. Changes to Australia's FOI laws in 2010, undertaken as part of a broader push for more open government, were designed to further improve transparency and support public engagement in government decision-making and policy development.[78] The Commonwealth's FOI laws are now arguably the most pro-disclosure among comparable jurisdictions in Australia and overseas. The 2010 reforms involved a reformulation of the 'public interest' test that is applied to FOI requests, creating a stronger presumption in favour of release (accentuated by listing the factors that must be considered in favouring release, but identifying none that count against).[79] Compared to other jurisdictions with Westminster-style systems, the Australian Government is now an outlier when it comes to making accessible frank and fearless advice that is intended to be provided to ministers in confidence. The United Kingdom (UK) and New Zealand Acts include specific exemptions to protect such advice.[80] The Queensland and Tasmanian Acts stipulate the factors that must be considered in favour of granting access and favouring non-disclosure.[81] Relevant legislation in most other Australian states applies a more balanced public interest test, similar to that in place at the Commonwealth level prior to the 2010 reforms.[82]

John Lloyd PSM

"FOI laws are very pernicious. I think they have gone beyond perhaps what they intended to do and I think they do make us a bit over cautious and make some of the advice more circumspect than it should be, and I hope the government will address that and perhaps reassess the extent of some of those FOI laws." (March 2015)[83]

John Lloyd is the Australian Public Service Commissioner

The Commonwealth's FOI laws now present a significant barrier to frank written advice. The Commonwealth laws have had the unintended consequence of constraining the content, form and mode of advice presented to ministers. Ironically, application of the revised public interest test has now had the unforeseen effect of lowering standards of public administration and, as a consequence, undermining the public interest in good policy. The public interest is certainly not served by having no public record of how and why decisions were made. Nor is there much benefit in gaining access to written advice that has purposefully been prepared to appear innocuous when released under FOI.

Former ministers and current and former agency heads have gone on the public record to say that the potential for public disclosure is constraining advice to ministers.[84] Today, when frank advice is required, it is too often delivered orally rather than being committed to writing. Fewer records are being kept, and the written advice that is provided is more likely to be anodyne, carefully constructed to minimise any sense of vigorous disagreement. The consequences include a patchy record of decision-making and an increased likelihood of decisions being made based on incomplete or poorly argued information. This can ultimately only be detrimental to good governance and the public interest.[85]

Advice that is honest and forthright is important. It ensures ministers make decisions with full knowledge of the facts and with their eyes open to the risks. The HIP involved instances where this did not occur. Of course, these failings took place prior to the 2010 reforms to the FOI laws but, given the impact of more pro-disclosure FOI laws since, one might conclude that public servants are even less disposed to offer frank written advice today.

In truth, the problems with the application of FOI legislation are deeper than the 2010 amendments. The FOI Act should be rebalanced to remove barriers to frank and fearless written advice being provided to ministers. The Act needs to explicitly recognise the value of robust perspectives in the advice process. In particular, the provision of frank advice and the benefits of a frank exchange of views as part of the deliberative process of government should be recognised as an important public interest consideration against providing access to documents.

A range of possible amendments to the FOI Act could support the above objective. The current public interest test, which is applied to requests for access to deliberative material, lists only factors that must be considered in favour of release. This could be rebalanced by listing those factors favouring non-disclosure (including the need to protect the frank and fearless advice given to a minister by a senior public servant). Alternatively—or in addition—an explicit exemption for frank and fearless advice could be introduced into the Act. The simplest and most attractive option under the current framework would be to strengthen the drafting of the current exemption for deliberative process to clearly describe the harm it seeks to avoid. This would make the construction of the exemption consistent with most others in the FOI Act and address the issue, identified by Allan hawke in his 2013 review of the Act, that "the absence of a clear indication of the harm that the exemption is designed to protect results in the exemption being subject to differing interpretations and difficult to apply."[86]

There would also be value in widening the current exemption for Cabinet documents to make it clear that it includes drafts, early advice and other preliminary material that may not ultimately be submitted to Cabinet, but which is of such close proximity that its release could impair the confidentiality of Cabinet processes. At the same time there would be benefit in implementing one of the recommendations made by Hawke in 2013: namely, to add an exemption to the FOI Act to cover incoming government and incoming minister briefs (a key part of helping to prepare governments for office), briefs written for question time and Senate Estimates hearings.[87] The public interest in protecting the confidentiality of these briefings has already been recognised in recent decisions of the Australian Information Commissioner.[88] The matter should be put beyond doubt.

Such modifications to the FOI Act would make the conditional exemption for 'deliberative matter' easier to apply but only in a limited set of circumstances—where disclosure of information could compromise the ability of public servants to provide ministers with frank advice.[89] It needs to be explained that this protection would apply only to a tiny proportion of government documents. In 2013-14 the exemption for deliberative matter was applied to only two per cent of all FOI applications.[90] The proposals should not, be misinterpreted as part of a move to limit access to government information more generally.

Indeed, making more government information accessible is important. The arguments put forward in Ahead of the Game: Blueprint for the Reform of Australian Government Administration in 2010, that "the Australian Government become more open and that public sector data be more widely available, consistent with privacy and secrecy laws," needs to be given full effect.[91] Major data sets and the factual information on how decisions are made should be in the public domain for all to use as they wish. Similarly, the results of policy and program evaluations should be made publicly available as a matter of course. With the huge advances in digital technology, shared information can build a stronger relationship between government and citizens. Equally important, individuals can often find new methods of using public information in unexpected ways to create public benefit.

Placing restrictions on freedom of information is extraordinarily sensitive. For that reason, the Government should undertake a thorough assessment of options for removing barriers to frank advice in the FOI Act. This should take into account not only the detrimental impact of existing legislation but relevant experience in comparable jurisdictions. It may be that a bipartisan group of former ministers, together with former Secretaries, could be appointed to investigate and report back to government on options and recommended approaches.

The duty of public servants to provide frank advice in writing needs to be made clear and unambiguous. The HIP Royal Commission asked whether the deficiencies highlighted in departmental record keeping were indicative of a broader deficiency across government.[92] They are. Indeed, it is surprising how many APS employees are unaware of their legal and professional obligations to record the business of government. As a result, record-keeping is too often treated as a low priority. This is something that should be corrected.

All significant advice and decisions that are part of an ongoing process of deliberation should be recorded. Much advice is part of an ongoing and iterative discussion. Part of the public servant's role is to assess the points at which a record is required. This might initially occur in an email or a diary note, but it is important that all documents that inform decisions find their way into formal records management systems. Proper record-keeping allows others in the future to fully understand the reasons for a decision or action.[93] In the case of sensitive information, records may be tightly held and only released to the public after considerable time has passed. The record is no less important in these circumstances.

Ensuring a record of decisions is more challenging in the digital age, when ministers, their offices and departments deal with massive volumes of information. Today, most written communication takes place not on paper but through electronic media, and the iterative process of policy development is regularly conducted over email and SMS. Unfortunately, the most comprehensive guide to APS recordkeeping was completed in 2007, well before the current proliferation of smartphones and tablets within government.[94] The APS should rebuild the discipline of good record-keeping and modernise it for the digital age. Texts matter.

A requirement to create records is implied, though not explicitly stated, in the Archives Act 1983. The ANAO notes the lack of a single clear and explicit requirement for the public servants to create records of all of its key business activities and decisions, although some categories of records are now specified under the PGPA Act.[95] Given the lack of consistency on record keeping, the National Archives of Australia should issue updated APS-wide guidance on the creation of new records, especially digital material, which should be endorsed by Secretaries. The foundation work to support such guidance is already underway.[96]

We need to go back to the first principles of the Westminster tradition. Ministers are elected and appointed to make decisions. It is in the public interest that they make themselves as well-informed as possible in carrying out these roles. Whether ministers choose to accept the arguments of a public servant must be up to them. They, and the governments they serve, should be judged in the court of public opinion on the decisions that they make, not on the advice they choose to reject. It is not in the public interest to undermine good public administration by deterring public servants from writing down the full force of the advice that their ministers need to read—nor by prompting ministers to ask for such advice to be conveyed orally. It is far better to have a deliberative document held confidentially than for it not to exist at all.

Conclusions | Providing robust advice

A.1 Public service advice is vital to good government and, to this end, Secretaries should be held accountable for the quality of advice provided to ministers by their departments.

A.2 Whilst acknowledging the value of frank and fearless oral discussions, the Australian public Service Commissioner should issue a Direction that significant advice also be provided to ministers in writing. Ministers should insist on receiving frank written advice from the APS, noting that it is generally their decision whether to accept or reject all or part of the advice.

A.3 The FOI Act should be amended to ensure that advice and opinion provided to support the deliberative processes of government policy formulation remain confidential.

A.4 An APS-wide policy on record keeping should provide practical guidance about when and how records must be created, including that records of deliberative discussions in all forms, including digital, should be retained.


Notes

[68] Scales, B 2014, p. 27; Hanger, I 2014, p. 83; Hawke, A 2010, p. 17.

[69] Scales, B 2014, p. 101.

[70] Hanger, I 2014, pp. 169, 302-303.

[71] Hanger, I 2014, p. 317.

[72] Hanger, I 2014, p. 307.

[73] Pezzullo, M 2014, 'Leading change in the Australian Public Service: The case of the Department of Immigration and Border Protection', speech to The National public Sector Managers and Leaders Conference, Melbourne, 17 April.

[74] Burgess, V 2015, 'Michael Thawley takes stock after first four months in top job', Australian Financial Review, 9 April.

[75] Government 2.0 Taskforce 2009, Engage: Getting on with Government 2.0, Australian Government Information Management Office, Canberra.

[76] Bovens, M 2005, 'Public Accountability' in E Felie, L Lynn & C Pollitt (eds.), The Oxford Handbook of Public Management, pp. 194-196, Oxford University Press, Oxford.

[77] Greber, J 2015 'Treasury's John Fraser blames media, FOI for bad policy', Australian Financial Review, 19 May.

[78] Office of the Australian Information Commissioner 2011, Guide to the Freedom of Information Act 1982, Australian Government, Canberra.

[79] Freedom of Information (FOI) Act 1982, section 11(b), (Commonwealth of Australia).

[80] Freedom of Information (FOI) Act 2000 (United Kingdom), Section 36; Official Information Act 1982 (New Zealand), s. 9(2)(g)(i).

[81] Right to Information Act 2009 (Queensland), Schedule 4; Right to Information Act 2009 (Tasmania),  Schedule 1.

[82] Freedom of Information Act 1982 (Victoria), Section 30; Freedom of Information Act 1991 (South Australia), Schedule 1, Part 3, Section 9(1); Freedom of Information Act 1992 (Western Australia), Schedule 1, Clause 6.

[83] Easton, S 2015, 'Government off the record: the limits of transparency', The Mandarin, 16 March.

[84] Evans, C 2013, 'Better policy responses: How well does the public service support ministers?', speech to the Institute of Public Administration Australia National Conference, Canberra, 21 November.

[85] Banks, G 2013, 'Restoring trust in public policy: what role for the public service?' Garran Oration 2013, speech to the Australian Institute of Public Administration, Canberra, 21 November.

[86] Hawke, A 2013, 'Review of the Freedom of Information Act 1982 and Australian Information Commissioner Act 2010', p. 48, Australian Government, Canberra.

[87] Hawke, A 2013, p. 49.

[88] Wright & Parnell and Department of the Prime Minister and Cabinet [2015] AICmr 13 (3 February 2015). See also Crowe and Department of the Treasury [2013] AICmr 69, Parnell & Dreyfus and Attorney-General's Department [2014] AICmr 71 and Crowe and Department of Prime Minister and Cabinet [2014] AICmr 72.

[89] Freedom of Information Act 1982, section 47(c), (Commonwealth of Australia).

[90] Office of the Australian Information Commissioner 2014, Annual Report 2013-14, pp. 135-136, Australian Government, Sydney, <http://www.oaic.gov.au/images/documents/about-us/corporate-information/annual-reports/annual-report-2013-14/Office-of-the-Australian-Information-Commissioner-Annual-report-2013-14.pdf>

[91] Department of the Prime Minister and Cabinet 2010, Ahead of the Game: blueprint for the reform of Australian Government administration, p. ix, Australian Government, Canberra.

[92] Hanger 2014, p. 319.

[93] The National Archives of Australia officially endorses the Australia Standard ISO 15489 for use by all Australian Government agencies.

[94] Management Advisory Committee 2007, Note for file—A report on record keeping in the APS, Australian Public Service Commission, Canberra, <http://www.apsc.gov.au/publications-and-media/archive/publications-archive/note-for-file>

[95] Australian National Audit Office 2012, 'Records Management in the APS and the public Governance, Performance and Accountability Act 2013 (PGPA Act)', Audit No 53 (2011-12), Canberra. The PGPA Act specifies records must be kept about performance (s. 37), and transactions and financial position (s. 41).

[96] 'Keep the Knowledge—Make a Record' is a training package development by the National Archives of Australia to assist all public servants and APS contractors to understand their obligations regarding records management. It explicitly includes all forms of digital messaging in the list of what constitutes a record and provides guidance on how to determine whether those records need to be saved in to the department records management system. Such training is valuable and should be more widely accessed. See National Archives of Australia 2015, 'Keep the Knowledge—Make a Record', <http://www.naa.gov.au/records-management/development/keep-the-knowledge/index.aspx?>