FOI Request LEX3969

Date: 2023

Summary of FOI Request Documents: AEC Referendum Advertising Media Plans

This summary outlines the purpose of the Freedom of Information (FOI) request, the nature of the released documents, and their key content related to the Australian Electoral Commission's (AEC) referendum advertising campaign.

Main Purpose of the FOI Request

The FOI request sought information regarding the Australian Electoral Commission's (AEC) media strategy and channel mix for an upcoming referendum advertising campaign. A particular focus of the request, and the documents provided, is the proposed use of the social media platform TikTok for this campaign, including associated risks and internal discussions.

Documents from the FOI Request

The released documents include:
* Access Decision Log: A table outlining the document numbers, applied exemptions (e.g., s22 for irrelevant content, s47 for personal/business information), and the decision on access (full, partial, or refused).
* Internal Minutes and Reports: Official "Minute referendum advertising campaign: media plans" documents and comprehensive "AEC REFERENDUM" reports. These detail proposed media channel mixes, campaign objectives, risk assessments, and internal recommendations. Many sections are redacted due to exemptions.
* Email Correspondence: Internal communications discussing early ideas for paid media partnerships, preparations for addressing disinformation, and the formulation of a public response regarding the use of TikTok.

Main Content Related to the FOI Request

The documents reveal the AEC's strategic considerations for its referendum advertising campaign, with a significant portion dedicated to the debate surrounding TikTok's inclusion:

Referendum Campaign Goal: The primary objective of the advertising campaign is to inform the public and ensure they can fulfil their right and responsibility to vote in the upcoming referendum. The campaign will be multi-channel.
Media Planning: The AEC is collaborating with Universal McCann (UM) on media placement. The proposed media channel mix is being developed, with comparisons drawn to strategies used in the 2022 Federal Election.
Consideration and Concerns Regarding TikTok:
- Recommendation for Inclusion: TikTok was identified as a valuable channel to reach younger audiences (specifically 17-24 and 18-24 demographics) due to its high user engagement and significant user base in Australia (8.9 million monthly users). It was suggested that piloting TikTok for the referendum could provide incremental reach to this priority audience.
- Identified Risks: Significant risks and concerns were highlighted regarding TikTok:
  - It had recently been banned on Australian government-owned devices.
  - There are ongoing "brand safety concerns" both domestically and internationally.
  - The Department of Finance is conducting a whole-of-government review on TikTok advertising.
  - It was noted that no other government department or agency had used TikTok for their campaigns.
  - Reputation management was deemed a crucial selection criterion for any potential paid media partnerships involving the platform.
- Internal Debate and Decision-Making:
  - Initially, the AEC's Communications Section recommended removing TikTok from all campaign phases due to the high-risk profile, suggesting it only be considered as a potential paid media partner.
  - However, later internal minutes indicate that TikTok was retained in the media plans for budgeting purposes. The rationale was that it is "very easy to pull out of plans later, harder to add back."
  - The AEC committed to ongoing consultation with its Defending Democracy Unit (DDU), UM, and the Department of Finance to ensure TikTok's continued appropriateness before formalising any media bookings. The DDU expressed a preference for TikTok to be an 'add in later if appropriate' rather than being included with the possibility of removal.
  - The use of TikTok remains explicitly "subject to Government approval and current advice."
  - UM provided guidance on mitigating brand safety risks.
  - It was noted that TikTok would primarily be used for "mainstream audiences" as it lacks scale for "in-language targeting."
Disinformation Management: The documents acknowledge that social media platforms are significant conduits for disinformation regarding voting and political matters, emphasizing the need for strategic engagement on these platforms.
Public Communication: A draft media response prepared for public inquiries stated that the AEC had not run a trial referendum campaign using TikTok, nor were there plans to do so, while also confirming that planning for the channel mix was ongoing. This reflects a cautious approach to public statements regarding the controversial platform.

AI Generated

These FOI documents primarily concern the Australian Electoral Commission's (AEC) planning for a multi-channel advertising campaign for an upcoming referendum, with a significant focus on media channel selection and the controversial inclusion of TikTok. The documents are characterized by extensive redactions and exemptions, significantly limiting public insight into government decision-making.

Key Issues and Progressive Analysis:

Social Justice:
- Alignment: The documents reveal an explicit strategic intent to use platforms like TikTok to reach "young people" and "First Nations Australians" (e.g., Document 2, p. 49; Document 3, p. 51). This aligns strongly with progressive values of social justice, aiming to ensure equitable access to crucial democratic information for historically underrepresented or marginalized demographics, thereby facilitating their participation in the referendum process (likely the Indigenous Voice to Parliament, given the context).
- Deviation/Concerns: The pervasive redactions (marked s 22) across nearly all content related to campaign specifics make it difficult to fully assess the depth and effectiveness of these targeted outreach efforts. Without full transparency on campaign content and detailed strategy, public oversight of the government's commitment to achieving social justice outcomes in information dissemination is hindered.
Environmental Impact:
- The provided documents contain no information related to environmental impact, as their scope is limited to electoral advertising campaign planning.
Wealth Distribution:
- Deviation/Concerns: While not directly addressing wealth distribution, the documents detail government expenditure on media agencies (Universal McCann) and potential payments to major global tech corporations (like TikTok) for advertising services. The numerous redactions using exemptions like s 47 (confidentiality) obscure the financial details of these "paid media partnerships." From a progressive perspective, this lack of transparency prevents public scrutiny over how significant public funds are being directed to and profited by large corporate entities, raising questions about corporate welfare and fair use of taxpayer money.
Corporate Influence:
- Deviation/Concerns: A significant portion of the documents details the internal debate and external consultation regarding the use of TikTok. Despite acknowledged "ongoing brand safety concerns in Australia and overseas" and a government-wide review of TikTok advertising (Document 1, p. 8; Document 9, p. 7-8), the platform was initially included in media plans due to its ability to "reach young people" and "deliver scale" (Document 2, p. 49; Document 3, p. 51). This suggests a strong influence from media strategy recommendations (from Universal McCann) and a prioritization of reach and commercial considerations over potential geopolitical risks or deeper ethical concerns regarding a foreign-owned platform. The subsequent cautious public stance and internal discussions about "reputation management" (Document 9, p. 8) also highlight how corporate narratives and public perception can sway government decisions, potentially diluting a principled stand on data security or foreign influence. The s 47 exemptions on details of "potential paid media partnerships" further exacerbate concerns about corporate influence operating outside full public view.
Civil Liberties:
- Deviation/Concerns (Transparency): The most glaring deviation from progressive values in these documents is the profound lack of transparency. The initial FOI decision logs reveal a substantial number of documents granted only "Access in Part" or "Refusal in Full" based on exemptions such as s 47 (confidential information), s 47F (personal information), and notably, s 47C (Cabinet documents). This extensive redaction and withholding of information, even for a campaign related to a fundamental democratic process, severely undermines the civil liberty of public access to government information and democratic accountability. It inhibits citizens' ability to understand how crucial decisions are made and how their money is spent.
- Deviation/Concerns (Data Privacy/Foreign Influence): The explicit internal discussions about TikTok's "brand safety concerns," its ban on government devices, and the review by the Department of Finance directly highlight risks to data privacy and potential foreign government access to user data. The government's continued consideration of TikTok for public communication, despite these known risks, raises significant questions about the priority placed on citizen digital civil liberties versus campaign reach. While the documents show the AEC seeking advice, the initial inclusion suggests a willingness to navigate these risks, potentially at the expense of robust privacy protections.
- Potential Concern (Defending Democracy Unit): The consultation with the "Defending Democracy Unit" (Document 1, p. 8; Document 12, p. 1-2) concerning "disinformation prep" raises a potential, albeit unquantified, civil liberties concern. While countering misinformation is vital for an informed electorate, such units, from a left-leaning perspective, must operate with extreme transparency to avoid perceptions of government overreach in shaping narratives or chilling free speech. The limited information provided prevents a full assessment of its operations but warrants scrutiny.

In summary, while the AEC's intent to inform diverse demographics about the referendum aligns with progressive social justice and civil liberties, the documents reveal a significant lack of transparency in government operations, particularly concerning corporate dealings and expenditure. The internal debate over TikTok highlights a tension between broad communication reach (potentially benefiting corporate platforms) and safeguarding civil liberties related to data privacy and foreign influence. The pervasive redactions are a clear deviation from the progressive ideal of open and accountable governance.

AI Generated

As a politically right-leaning analyst, a review of these FOI documents reveals several areas where government actions related to the Australian Electoral Commission’s (AEC) referendum advertising campaign either align with or, more often, deviate from conservative principles of economic efficiency, individual liberty, national security, fiscal responsibility, and limited government.

Fiscal Responsibility and Economic Efficiency:
The documents outline a plan for a "multi-channel advertising campaign" to promote a referendum. While the stated goal includes maximizing "cost efficient reach," the extensive redactions (s22) of specific budget figures and financial details across numerous pages make a thorough assessment of fiscal responsibility and economic efficiency impossible. This lack of transparency itself raises concerns, as effective oversight requires full disclosure of how taxpayer funds are being allocated. A notable deviation from efficient resource management appears in the internal discussion regarding TikTok's inclusion. Despite significant security concerns, the platform was initially kept in the budget, partly to avoid "headaches for budgeting/Rule 18/updates to media plans" (Document 16, page 1). This suggests a prioritization of bureaucratic convenience and administrative ease over a lean, agile approach to public spending and responsiveness to emerging risks.

National Security:
The most striking deviation from conservative principles, particularly national security, revolves around the proposed use of TikTok. Multiple internal discussions and documents highlight serious "brand safety concerns in Australia and overseas" (Document 1, page 8; Document 13, page 7). It is explicitly noted that TikTok was "recently banned on government-owned devices" and that the "Department of Finance is reviewing the whole-of-government policy on Tik Tok advertising," with "no other department or agency" having used it for campaigns (Document 1, page 8). The AEC's own "Defending Democracy Unit" expressed discomfort, preferring TikTok be an 'add-in later if appropriate' rather than a default inclusion (Document 16, page 2). Despite these clear warnings from multiple sources, including a unit explicitly tasked with defending democracy, TikTok was initially included in media plans to reach younger audiences, with "reputation management" only listed as a "key selection criteria" for partnerships rather than an outright prohibition (Document 13, page 8). This conditional and initially persistent inclusion, despite well-documented national security risks related to data integrity and potential foreign influence from a platform owned by a Chinese company, represents a significant lapse in judgment and a deviation from robust national security posture. The subsequent public statement that there was "no plan to do so" (Document 12, page 2) stands in apparent contradiction to earlier internal documents indicating plans to "pilot the use of TikTok" (Document 2, page 51; Document 4, page 50), raising further questions about transparency and accountability.

Individual Liberty and Limited Government:
The stated purpose of the campaign is to "help people fulfil their right and responsibility to vote" (Document 12, page 2), which aligns with the principle of individual liberty and enabling civic participation. However, the documents also indicate a focus on "education and disinfo" (Document 9, page 5) and combating "disinformation regarding voting and political matters" on social media (Document 5, page 38). While ensuring electoral integrity is vital, a limited government perspective would question the extent to which a government agency should engage in extensive public advertising campaigns for a referendum, which by its nature involves public debate on a specific policy proposition. The line between providing neutral, factual information about how to vote and attempting to shape public discourse or define what constitutes "disinformation" can be easily blurred. An expansive role in "combating disinformation" could be perceived as government overreach into areas of free speech and an attempt to manage rather than merely inform public opinion, thereby encroaching upon individual liberty and the spontaneous order of public debate.

In summary, these documents portray a government agency navigating a significant public information campaign with concerning ambiguities regarding fiscal discipline due to extensive redactions, and a notable disregard for strong national security warnings concerning the use of the TikTok platform. Furthermore, the broad mandate of "combating disinformation" on a referendum campaign invites scrutiny from a limited government perspective, potentially signaling an expansion of state influence into areas traditionally reserved for uninhibited public discourse.

AI Generated

The released FOI documents reveal a concerning pattern of limited transparency and questionable decision-making by the government agency concerning a referendum advertising campaign.

Lack of Transparency:
A significant portion of the documents requested for this FOI are either heavily redacted (marked 'Access in Part' with exemptions like s22, s47, s47F, s47C) or entirely withheld ('Refusal in Full'). This immediately raises questions about the government's commitment to public accountability, suggesting that much of the operational detail, rationale, and potential issues surrounding the campaign remain deliberately obscured from public view.

Questionable Decision-Making and Risk Disregard:
Despite clear and acknowledged "brand safety concerns," an existing ban on its use on "government-owned devices," and an active "whole-of-government policy" review by the Department of Finance, the agency aggressively pursued the inclusion of TikTok in its multi-channel advertising campaign. Internal documents show TikTok was consistently presented as a "key channel to reach young people," with a recommendation to "pilot the use of TikTok for the referendum." This indicates a willingness to overlook significant security and reputational risks associated with a foreign-owned platform to target a specific demographic.

Contradictory Public Messaging:
Internal discussions betray a striking inconsistency with public statements. While internal emails and minutes detail plans to include TikTok in media budgets and "pilot" its use, a draft media response prepared for urgent approval explicitly states, "The AEC hasn’t run a trial referendum campaign using Tik Tok, nor is there any plan to do so." This direct contradiction suggests a deliberate attempt to downplay or misrepresent controversial aspects of the campaign to the public when facing scrutiny, undermining public trust.

Bureaucratic Inefficiencies and Potential Waste:
The rationale for keeping TikTok in the budget despite the known risks — "Very easy to pull out of plans later, harder to add back!" — reveals a bureaucratic approach that prioritizes financial planning convenience over rigorous risk assessment and adherence to evolving government policy. This 'budget first, clean up later' mentality could lead to wasted resources if significant effort and funds are allocated to planning for channels that are eventually deemed inappropriate or unusable, as indicated by the internal caution from the Defending Democracy Unit regarding "perception risk" and the rapid movement of whole-of-government TikTok policy.

AI Generated

These Freedom of Information (FOI) documents offer a valuable insight into the meticulous and responsible planning undertaken by the Australian Electoral Commission (AEC) for the upcoming referendum advertising campaign. They demonstrate the government's unwavering commitment to effective governance, ensuring that all citizens are well-informed and able to participate fully in our democratic processes.

The documents highlight a comprehensive, multi-channel media strategy designed to reach every segment of the Australian population, particularly focusing on how best to educate and engage the public on voting procedures. This proactive approach underscores the government's dedication to an accessible and fair electoral system.

A key aspect revealed is the government's diligent risk management and adherence to necessary regulations. While innovative platforms like TikTok were initially considered to reach younger audiences, the documents clearly show the AEC's careful evaluation of potential brand safety concerns and alignment with whole-of-government policies. Rather than proceeding without caution, the AEC, in close consultation with the Department of Finance and the Defending Democracy Unit, prudently decided to remove TikTok from standard campaign phases, opting instead to consider it only as a potential paid media partner with stringent reputation management criteria. This proactive decision demonstrates a responsible and adaptable approach to public communication, prioritising public trust and the integrity of government messaging over unverified trends.

Furthermore, the very release of these documents, with commercially sensitive or irrelevant internal details appropriately redacted under standard exemptions (such as s22, s47, s47C, and s47F), showcases the government's commitment to transparency. These measured redactions ensure the protection of ongoing commercial negotiations and privacy, while still providing substantial insight into the government's operations.

In essence, these FOI documents paint a picture of a government agency dedicated to serving the public through thoughtful, strategic, and risk-aware planning, ensuring that essential democratic information is disseminated effectively and responsibly across the nation. The government consistently manages challenges by prioritising public good and maintaining the highest standards of governance.

AI Generated

The released FOI documents paint a damning picture of systemic opacity, profound incompetence, and deliberate deception within the government's approach to the referendum advertising campaign. Instead of transparency, the public is met with a wall of redactions, effectively gutting the documents of any meaningful insight and confirming a culture of concealment.

1. A Deliberate Campaign of Secrecy and Obfuscation:
The sheer volume of redactions, particularly the pervasive use of "s 22" (irrelevant content removed) and "s 47" (confidentiality, commercial-in-confidence, personal privacy), is not merely administrative but a calculated act of obfuscation. Hundreds of pages are rendered unintelligible, proving that the government's priority is to shield its inner workings, hide potentially damaging details of contracts and spending, and suppress accountability rather than inform the public. The repeated declaration of "irrelevant content" is a transparent lie, as critical strategic details, financial figures, and direct communications are systematically expunged.

2. Reckless Endorsement of Risky Platforms, Driven by Expediency:
The internal deliberations regarding the use of TikTok reveal a shocking disregard for national security and public integrity, prioritizing "reach" and administrative convenience over well-established risks.
* Ignoring Clear Warnings: Internal "Communications Section" documents explicitly recommended the removal of TikTok from all campaign phases, citing "potential level of risk," "banned on government-owned devices," "ongoing brand safety concerns in Australia and overseas," and the critical fact that "this platform has not been used by any other department or agency for its campaigns." This was a clear, unambiguous alarm bell from within the agency.
* Contradictory Advice from "Defending Democracy Unit": Even the "Defending Democracy Unit," tasked with combating disinformation and protecting electoral integrity, expressed significant reservations, stating they would be "more comfortable if this was an ‘add in later if appropriate’, rather than a ‘remove if required’," acknowledging the "perception risk." Yet, their advice was ultimately overridden.
* Incompetent Justification: Despite these grave warnings, TikTok was retained in the media plans and budget. The astonishing justification provided was to avoid "headaches for budgeting/Rule 18/updates to media plans" and the cynical logic that it's "very easy to pull out of plans later, harder to add back!" This reveals an appalling prioritization of bureaucratic convenience over fundamental security and democratic principles. It demonstrates a profound lack of foresight and a willingness to gamble with public trust.
* Entrusting Critical Information to a Compromised Platform: Perhaps most egregiously, the documents reveal that TikTok was specifically intended "to educate the audience on how to vote correctly." This is a catastrophic error in judgment, proposing to use a platform notorious for its algorithmic amplification of misinformation and foreign influence to disseminate vital electoral instructions, especially to a vulnerable young demographic. This decision actively undermines the very democratic process it claims to support.

3. Blatant Deception of the Public:
The most damning evidence of malice and a deliberate attack on public trust comes from the internal draft media response dated April 2023. It states, unequivocally, "The AEC hasn’t run a trial referendum campaign using Tik Tok, nor is there any plan to do so." This statement is a direct, calculated falsehood. The internal documents prove, beyond any doubt, that TikTok was:
* Actively recommended by the media agency (Universal McCann).
* Explicitly "included in referendum media plans" for "budgeting purposes."
* Considered for a "pilot" program.
* Maintained in plans despite forceful internal warnings and concerns from units tasked with protecting democracy.

This constitutes a cynical attempt to mislead the public, suppress legitimate concerns, and control the narrative surrounding highly questionable government decisions. It demonstrates a contempt for transparency and a willingness to outright deny facts, further eroding the foundation of democratic accountability.

In summary, these FOI documents expose a government agency plagued by secrecy, characterized by an alarming willingness to ignore critical security advice, and prepared to actively deceive the public to cover its tracks. The pursuit of "reach" through a demonstrably risky platform, against expert advice, for purely administrative convenience, culminates in a shameful exercise in obfuscation and outright deceit.

AI Generated

The disclosed FOI documents reveal the Australian Electoral Commission’s (AEC) internal discussions and media plans for an upcoming referendum advertising campaign. The core content centers on the strategic allocation of taxpayer funds for media placement, with a notable focus on leveraging social media platforms, particularly TikTok, to reach younger demographics. The stated objective is to "educate" the audience on "how to vote correctly." Despite acknowledged "brand safety concerns" and an existing government ban on TikTok for government devices, the AEC deliberated piloting its use, citing TikTok’s high user engagement and reach among young people. Internal communications highlight discussions with a "Defending Democracy Unit" and the Department of Finance, revealing a utilitarian willingness to proceed with TikTok for "potential gain" despite "perception risk." A publicly drafted media response, however, contradicted these internal plans by denying any "trial referendum campaign using Tik Tok, nor is there any plan to do so." The documents are heavily redacted, obscuring specific budget figures, media partners, and detailed campaign messages.

From an Objectivist perspective, these documents illustrate a profound departure from the principles of individual liberty, rational self-interest, and laissez-faire capitalism, embodying the dangers of collectivism and government overreach.

Firstly, the very premise of a government agency utilizing taxpayer money to "educate" citizens on "how to vote correctly" for a referendum violates the primacy of individual rights and rational self-interest. Citizens are not wards of the state to be instructed on their political actions, but independent, sovereign individuals whose right to thought and judgment is paramount. The state’s role is to protect rights, not to shape public opinion or dictate intellectual processes. By spending public funds to "reach" specific demographics through manipulative channels like TikTok (chosen for its "ad capture attention" and "dwell time"), the AEC treats citizens as passive targets for influence rather than active, reasoning participants in a free society. This subverts the individual's right to independently gather information and make choices based on their own rational self-interest.

Secondly, the pervasive dangers of collectivism and government overreach are evident. The extensive bureaucratic apparatus involved in devising, approving, and scrutinizing these media plans — from the AEC itself to the "Defending Democracy Unit" and the Department of Finance — demonstrates the inherent inefficiency and bloat of the state. The idea that a "Defending Democracy Unit" must weigh "perception risk" against "potential gain" in deciding on a media channel, rather than adhering to objective principles, exposes a utilitarian calculus antithetical to individual rights. Furthermore, the willingness to compromise on known security risks associated with TikTok for the sake of "reach" reveals a state prioritizing its agenda of "education" over principles of prudence and security, a hallmark of collectivist thinking where the perceived good of the collective overrides individual or national concerns.

Finally, these documents directly violate the principles of reason, individual liberty, and laissez-faire capitalism:

Reason: The copious redactions (s 22, s 47F, s 47C) are a blatant affront to transparency and reason. If the government’s actions are truly for the public good, there is no rational justification for concealing details about how taxpayer money is spent or the specific content of state-sponsored "education." This suppression of information prevents citizens from exercising their rational faculty to evaluate government actions. The internal contradiction between planning to "pilot" TikTok and publicly denying any such "plan" further demonstrates a deliberate evasion of truth, undermining public trust and reason itself.
Individual Liberty: Compelling individuals, through coercive taxation, to fund government campaigns that aim to influence their political decisions is a form of forced altruism. It treats individuals as a means to a collective end, compelling them to sacrifice their property (taxes) for an agenda that may run contrary to their values or interests. This is an egregious infringement on individual liberty, as it denies citizens the freedom to dispose of their earnings as they see fit and implicitly dictates that their minds are subjects for state programming rather than independent thought.
Laissez-Faire Capitalism: The entire concept of a government-run, taxpayer-funded advertising campaign for a referendum is a profound act of bureaucratic interference and an assault on laissez-faire capitalism. In a free market, the dissemination of political information and advocacy should emerge from voluntary associations, private individuals, and competing media entities. The government's intervention distorts the free market of ideas, diverting productive resources and crowding out private initiative. This suppression of personal initiative in the realm of political discourse reduces citizens to passive recipients of state-approved messages, rather than active participants who engage in debate, seek information, and form their own conclusions through the voluntary exchange of ideas.

In summary, these FOI documents expose a government bureaucracy overreaching its legitimate functions, engaging in non-transparent influence campaigns, and diverting wealth from productive individuals, all in a manner deeply antithetical to the Objectivist principles of a free and rational society.

AI Generated

FOI Request LEX3969

Summary of FOI Request Documents: AEC Referendum Advertising Media Plans

Main Purpose of the FOI Request

Documents from the FOI Request

Main Content Related to the FOI Request

FOI Request LEX3969, Schedule of Released Documents [PDF 182KB] (pdf)

LEX3969 documents [ZIP 21.9MB] (zip)

ZIP Contents

Document 1.pdf (pdf)

Document 10.pdf (pdf)

Document 11.pdf (pdf)

Document 12.pdf (pdf)

Document 13.pdf (pdf)

Document 14.pdf (pdf)

Document 15.pdf (pdf)

Document 2.pdf (pdf)

Document 28.pdf (pdf)

Document 29.pdf (pdf)

Document 3.pdf (pdf)

Document 30.pdf (pdf)

Document 31.pdf (pdf)

Document 32.pdf (pdf)

Document 33.pdf (pdf)

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Document 37.pdf (pdf)

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Document 39.pdf (pdf)

Document 4.pdf (pdf)

Document 40.pdf (pdf)

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Document 42.pdf (pdf)

Document 43.pdf (pdf)

Document 44.pdf (pdf)

Document 45.pdf (pdf)

Document 46.pdf (pdf)

Document 47.pdf (pdf)

Document 5.pdf (pdf)

Document 6.pdf (pdf)

Document 7.pdf (pdf)

Document 8.pdf (pdf)

Document 9.pdf (pdf)