Policy
Team: Corporate
Communications
Title:
Making public comment
Version no:
2
Effective date:
December 2013
FOI exempt:
Yes
Director, Corporate Communications and Strategic
Approved by:
Change
BACKGROUND/INTRODUCTION ................................................................................................. 2
SCOPE ........................................................................................................................................... 2
POLICY .......................................................................................................................................... 2
EXCEPTIONS ................................................................................................................................ 3
DRIVERS ....................................................................................................................................... 3
CONSEQUENCES ......................................................................................................................... 3
REFERENCES ............................................................................................................................... 3
DOCUMENT AND FOI RELEASE ADMINISTRATION ................................................................. 4
FOI Document Release .................................................................................................................. 5
Policy Version No:
V2
Title: Making public comment
Effective Date:
December 2013
PMC/2012/200
Next Review Date:
December 2014
Template Version
V7
WARNING: Printed versions of this document may not be current.
Page 1 of 5
BACKGROUND/INTRODUCTION
The Australian Public Service Commission (APSC) has developed guidance for APS agencies
and APS employees on their rights and obligations when making public comment.
This policy reinforces the APSC's guidance and aims to provide balanced and fair treatment of
ComSuper's rights to protect its reputation and the rights of ComSuper's staff to reasonable
freedom of expression when making public comment.
ComSuper recognises that interested and engaged professionals are an asset to the
organisation and that staff can increase their technical knowledge and personal effectiveness
through productive exchanges with other professionals. This may occur in many ways including
online, over the phone, in person, or through published materials.
APS employees need to ensure that they understand the APS Values and Code of Conduct and
how they apply to official or personal communications.
The Code of Conduct requires all employees to 'at all times behave in a way that upholds the
APS Values and the integrity and good reputation of the employees Agency and the APS'.
SCOPE
This policy applies to all ComSuper staff in both a professional and personal capacity.
The term ‘public comment’ is used broadly, and includes comment made on ComSuper's
operations, work related matters and personnel.
Methods of making public comment may include, but not be limited to, the following:
in written publications; including books, journals, newspapers and letters
at all public speaking engagements; including conferences and media interviews
on internet sites that allow user participation and interaction; including social networking
sites, blogs, chat sites, forums or news websites
any other forum where comment is facilitated and may be accessed by the community.
POLICY
The making of public comment by a ComSuper staff member must comply with the APS Values
and Code of Conduct and the APSC's guidance for APS employees as outlined in
Circular
2012/1: Revisions to the Commission's guidance on making public comment and participating
online.
ComSuper staff are required to obtain written authorisation from a member of ComSuper's
Executive Committee, preferably their branch manager, prior to making public comment on
ComSuper's operations, work related matters and personnel.
Policy Version No:
V2
Title: Making public comment
Effective Date:
December 2013
PMC/2012/200
Next Review Date:
December 2014
Template Version
V7
WARNING: Printed versions of this document may not be current.
Page 2 of 5
ComSuper staff must have this authorisation and content approval before presenting, discussing
or publishing any wider information relating to ComSuper's operations, work related matters and
personnel. This includes, but is not limited to, any comment that:
commits ComSuper to any action or initiative
attempts to speak, or could be interpreted as speaking, on behalf of ComSuper
relates to controversial, sensitive, confidential or political matters
could be interpreted as a personal political view or political advocacy
could bring ComSuper, the Commonwealth Superannuation Corporation or our relevant
Ministers into disrepute.
ComSuper staff do not need to seek clearance when talking about factual, unclassified matters
related to ComSuper.
EXCEPTIONS
There are no exceptions to this policy.
DRIVERS
The drivers for this policy are:
the release of guidance provided by the APSC:
Circular 2012/1: Revisions to the
Commission's guidance on making public comment and participating online
increasing uncertainty and/or lack of awareness about permitted behaviours
increasing availability of opportunities to engage intentionally and unintentionally in public
comment
availability of access from ComSuper workstations to sites that provide avenues for
public comment.
CONSEQUENCES
In the event of a breach of this policy, disciplinary measures may be taken at the managerial
level. Serious breaches may result in action under the APS Code of Conduct.
REFERENCES
Documents that relate to making public comment and this policy:
APSC's
Circular 2012/1: Revisions to the Commission's guidance on making public
comment and participating online
The APS Values and Code of Conduct
Refer to the information technology policy section on the intranet for a listing of relevant
IT related policies. It is the responsibility of all staff to be aware of, and comply with, all
relevant policies and procedures.
Policy Version No:
V2
Title: Making public comment
Effective Date:
December 2013
PMC/2012/200
Next Review Date:
December 2014
Template Version
V7
WARNING: Printed versions of this document may not be current.
Page 3 of 5
DOCUMENT AND FOI RELEASE ADMINISTRATION
Approvals – Document content and FOI Release
All documents must be approved by the relevant EL1 or above
Date
Version
Name
Position
3/12/2013
2
Director, Corp Comms and Strategic Change
19/09/2012 V1
Executive Manager, Corp Strategy and Support
Revision History
Date
Version Drafter’s Name
Drafter’s Position
Reason for Revision
3/12/2013
2
A/g Manager, Corp C
Annual update
19/09/2012 0.6
Executive
Manager,
Grammatical editing
Corporate Strategy
and Support
18/09/2012 0.5
Manager Corporate
Minor clarification
Communications
amendments
20/07/2012 0.4
Manager Corporate
Amendments from
Communications
Executive Committee
5/06/2012
0.3
Manager Corporate
Input from Manager
Communications
Corporate Comms
and EM Comms
9/12/2011
0.2
Assistant Director,
New policy
Audit & Risk
10/12/2012 0.1
Assistant Director,
Input from CIO and
Audit & Risk
EM HR
Document Owner
Date
Document Owner (i.e. section responsible for the document)
5/06/2012 Corporate
Communications
10/12/2011
Audit & Risk
Required Consultation (mandatory for major changes)
Date
Document Owner (i.e. section responsible for the document)
23/08/2012
Workplace Relations Committee
12/06/2012
Paper to the Executive Committee
20/01/2012
, Executive Manager, Communications
8/12/2011
, Chief Information Officer
8/12/2011
, A/g Executive Manager, Human Resources
Policy Version No:
V2
Title: Making public comment
Effective Date:
December 2013
PMC/2012/200
Next Review Date:
December 2014
Template Version
V7
WARNING: Printed versions of this document may not be current.
Page 4 of 5
FOI Document Release
All documents will be released unless a direction to exempt is provided by document owner.
The list of exemptions is displaying in the table below. If you require advice regarding FOI or
exemptions, please contact your scheme FOI/Legal team.
Exemption Explanation
Only check
if an
Number
Exemption
applies
This document is not used to assist ComSuper to exercise its functions or
X
FOI- N/A
powers in making decisions or recommendations that affect members of the
public
33
Documents affecting national security, defence or international relations
34
Cabinet documents
37
Documents affecting enforcement of law and protection of public safety
38
Documents to which secrecy provisions of enactments apply
42
Documents subject to legal professional privilege
45
Documents containing material obtained in confidence
Documents disclosure of which would be contempt of Parliament or contempt
46
of court
47
Documents disclosing trade secrets or commercially valuable information
47A
Electoral rolls and related documents
s 47B
Cause damage to Commonwealth-State relations *
s 47C
Deliberative processes *
Substantial adverse effect on the financial or property interests of the
s 47D
Commonwealth *
s 47E
Prejudice/substantial adverse effect on certain operations of agencies *
s 47F
Unreasonable disclosure of personal information *
s 47G
Unreasonably affect business *
s 47H
Research (unreasonably expose agency/officer to disadvantage) *
s 47J
Substantial adverse effect on the economy *
* Public interest conditional exemption
Policy Version No:
V2
Title: Making public comment
Effective Date:
December 2013
PMC/2012/200
Next Review Date:
December 2014
Template Version
V7
WARNING: Printed versions of this document may not be current.
Page 5 of 5
