Online Consultation Guidelines

These guidelines are being developed as part of trials of online consultation being conducted by the Australian Government. They will be expanded and developed on the basis of the experience of the trials and incorporated into the Web Publishing Guide.

The Australian Government is interested in employing the emerging capabilities of the web, known as Web 2.0, to engage with the public in an open and transparent manner. These Interim Guidelines are provided to assist agencies in leveraging the increasing interactivity of the internet to augment their consultations with their stake-holders and the public.

Consultation Design Parameters

Consideration of the following matters will assist agencies in developing their approach to online consultation.

Purpose

For effective consultation, government agencies, officials and Ministers should have a clear idea of the purpose of the proposed online consultation activity. This should include consideration, not only the subject of the consultation, but also more general objectives. The purpose of a consultation activity should inform and guide the choice of the most effective method of consultation.

What is the purpose of the consultation? This might include one or more of the following.

  • To gather information
  • To gauge sentiment in respect to a proposal or policy (are people for or against it?)
  • To inform policy development
  • Community involvement
  • To generate debate
  • To generate new ideas

Subject

The subject of the consultation is closely related to the purpose and along with consideration of the intended audience.

What is the subject of the consultation? Apart from the name of the consultation how would you describe it?

  • Narrow, technical, sectoral, with specific questions?
  • More general, but with a clearly identified subject?
  • Open-ended, no specific subject?

Audience

Government agencies, officials and Ministers should have a clear idea of the audience they wish to engage in any online consultation process. This may be broad and general in some cases, but in other cases where the subject is technical or sectoral in nature, the intended audience may be a specific group of experts and practitioners.

What is the intended audience of your consultation? Is it:

  • a clearly identified community, sector or industry (peak bodies, lobby groups, experts and practitioners)?
  • Anyone interested in a specific subject?
  • Open-ended, anyone who is interested in participating?

Who is consulting?

The nature of the entity conducting the consultation should also influence consideration of the form of consultation. This would also involve consideration of the role of the individual or entity conducting the consultation. For example a Minister may consult in their political capacity as a member of a party or in an official capacity as a Minister of State. This would have a significant bearing on the appropriate form of consultation. The Guidelines for Ministerial and Departmental Websites (which are part of the Web Publishing Guidelines) contain more information on the distinction between the use of websites for political statements and government business.

Who is consulting?

  • A Minister?
  • A Royal Commission?
  • A Parliamentary Committee?
  • An independent or eminent person?
  • A government official (such as a Commissioner)?
  • A Government agency or department?

Who is enabling the consultation?

In some cases the entity officially conducting the consultation will not be enabling, managing or maintaining the consultation interface. This may be an agency in a Minister's portfolio or a commercial entity in an outsourced scenario. This may be a particularly important consideration as the relationship between the two relevant entities may not be clear, in respect to accountability, reporting and cost. The relationship between these two entities should be clearly defined and documented in some form of written agreement or contract, which clearly sets out the roles and responsibilities of each party.

Who is enabling the consultation?

  • An organisation independent from government?
  • Parliament?
  • A Government agency?
  • Out-sourced service provider contracted by a government agency?
  • Existing non-government forum (such as Open Forum)?

Forms of Online Consultation

There are several forms of online consultation with varying degrees of interactivity and different functionality. A policy framework aligning different forms of online consultation with the considerations above is being developed and will be published later. In the meantime the forms commonly in use are briefly reviewed below.

Traditional Online Consultation

In its simplest form this involves the online publication of a discussion paper with submissions being accepted in electronic form, generally via email. This approach is usually based on a consultation website in which the submissions may be published at selected intervals during the consultation or at the end of the consultation period. A variation of this model may involve the real time publication of comments submitted via a web form.

Discussion fora

These can be hosted on websites or email lists. All members or subscribers can post to the forum and any member can post comments. Membership can be open or restricted.

Blogs

These usually involve a monologue by the blogger (which can be text, audio/visual or video) with readers able to respond by adding comments via a web form. A dialogue can develop between the blogger and those who comment but may not. Blogs can be hosted by an individual or a community and group blogs may resemble other web or email based discussion fora.

Social Networks

These are web-based online communities where users interact and communicate with each other. These include MySpace, Facebook and Bebo. YouTube is a video based social network and there are also music based social networks such as Last.fm.

Idea Generation fora

These can be similar to blogs or discussion fora, but are dedicated to inviting creative or problem solving input from the public, usually in respect to a particular issue or subject.

Wikis

Wikis are platforms for collaboration, where users can collectively produce and edit content (usually text). The most famous example is Wikipaedia, which is an online encyclopaedia created collaboratively by its users. The New Zealand Government has used a wiki to re-write the New Zealand Police Act.

Interactivity

The models above can be supplemented with various features to enhance interactivity. Some of these are briefly described below.

Voting and rating systems

These are commonly used on e-commerce platforms as recommendation engines. Users are invited to indicate their support, or otherwise, of a product in a binary fashion or by applying a numerical rating.

Tagging

Tagging is widely employed on blogs and social networks and allows users to tag text and other artefacts with descriptive keywords. This permits search and aggregation based on the tags applied.

RSS and Atom feeds

Users can subscribe to these feeds to be alerted when items of interest to them are published on a website, blog or social network.

Co-ordination with other channels

Consultation with the community is a standard part of government policy development. Before the internet, governments consulted using available channels such as public meetings and hearings, publishing discussion papers and inviting written submissions and using the broadcast media. The internet does not replace any of these channels and most government consultations will involve several channels including the internet.

What channels does your consultation employ?

  • Written submissions?
  • Public meetings or hearings?
  • TV and radio appearances?
  • Articles in newspapers and print media?
  • A website?

It will be important to carefully co-ordinate use of these various channels and manage them with a Communications Plan. There is immense scope for synergy between multiple channels and cross-promotion. For example a website can publish a schedule of public meetings and represent them geographically as well as host video or photo reportage of the public meetings.

Controls

Online fora have developed several control mechanisms relating to membership and the rights and responsibilities of hosts and participants. These include registration and authentication, privacy, acceptable use policy and terms and conditions.

Registration/Authentication

The development of an appropriate approach to user registration and/or authentication is a fundamental consideration in the development of your consultation and is closely related to the purpose of the online consultation.

A minimal approach is probably the best as research indicates that people may be discouraged from participating if they have to provide too much personal information. Requirements will vary with different consultation objectives and models. It is important to design the registration and/or authentication approach so that it is fit for the purpose of the consultation. Any collection of the personal information of participants in online consultations must comply with the Privacy Act 1988.

Questions to consider are listed below.

  • Is it necessary to know who is providing input?
  • What is the minimum set of personal information that that needs be collected in order to register a participant in the online consultation?
  • Can a user specify whether their personal information is to be kept private and not be published either online or in any draft or final report?
  • What measures can be employed to ensure that a user has only one account and to prevent a user from flooding the consultation with multiple submissions purporting to be from several participants?
  • What measures are taken to protect any personal information collected from unauthorised disclosure, misuse or loss?

Privacy

Australian Government agencies must comply with 11 Information Privacy Principles (Privacy Commissioner) which are set out at section 14 of the Privacy Act 1988(Commonwealth) (Privacy Commissioner).

It is recommended that Australian Government agencies complete a Threshold Assessment (Privacy Commissioner) to determine, early in the developmental stages of an online consultation, whether that project is likely to require a Privacy Impact Assessment (PIA) (Privacy Commissioner). The Office of the Privacy Commissioner provides advice on the completion of a PIA and refers specifically to where an agencies project involves the collection, use or disclosure of "personal information".

The collection of personal information may not be necessary or appropriate for every online consultation. Only collect personal information if necessary, and as appropriate to the consultation, collect as little personal information as possible. Agencies must be aware of the importance of a Privacy Statement in respect to any collections of personal information (IPP 2) (Privacy Commissioner).

Acceptable Use Policy

The purpose of the Acceptable Use Policy is to provide a safe environment where people are able to publicly contribute their views to the consultation forum, to improve government policy, engender a sense of community, without fear of abuse or harassment or exposure to offensive or otherwise inappropriate content and protecting the operators of the consultation forum from legal liability. The Acceptable Use Policy can also set the parameters of the Moderation Policy clearly indicating what forms of behaviour are not permitted. Acceptable Use Policies generally establish conditions for participation in an online consultation or community and typically include the following requirements.

  • Protect your personal privacy and that of others by not including personal information of either yourself or of others in your posts to the forum, (such as names, email addresses, private addresses or phone numbers)
  • Post material to the forum that is relevant to the issues currently being consulted on
  • Represent your own views and do not impersonate or falsely represent any other person
  • do not be abusive, harass or threaten others
  • do not make defamatory or libellous comments
  • avoid vilification that is prohibited by anti-discrimination law
  • not use obscene or offensive language
  • not post material to the forum that infringes the intellectual property rights of others
  • not post multiple versions of the same view to the forum
  • not promote commercial interests in your posts to the forum
  • do not include internet addresses or links to websites, or any email addresses, in your contribution

Moderation

The topic of moderation raises considerable issues. In a political environment moderation may be perceived by the community as censorship. For the community to have confidence in the process of consultation they must have confidence in the moderation process itself.

Moderation should be based on explicit policies that are easy to access and understand by users. The moderation process needs to be supported by a policy framework that includes a content policy, take down policy and associated grievance procedure.

It should be noted that moderation is only applicable to some online consultation models (not relevant to traditional online consultations). It is recommended that agencies develop a moderation policy consistent with the objective, subject and consultation mechanism.

As a minimum Australian Government agencies should employ a technical or automated moderation process that can deal with profanities. Human moderation may be required for other kinds of offensive content, or off topic submissions, so it is likely that some online consultations will require a mixed model for moderation. For example, a technical solution to filtering of objectionable words (a black list) and a human solution to moderation of posts that do not meet the content policy.

Moderation by humans can be very resource intensive. Consultations that generate hundreds or possibly thousands of posts will not be able to be scanned by humans on a post-by-post basis unless sufficient person resources are made available to do so.

It is prudent for agencies to employ a risk management approach to Moderation that includes:

  • Publishing a ‘take down policy’ for infringements of the Acceptable Use Policy
  • Implementing a procedure for informing a user (when their contact details are valid) that their post is being removed and why, referring them to the appropriate part of the content policy and the grievance procedure – that is, openness and communication are important to keep confidence in the moderation system
  • Use of an additional system which enables a user to report offensive content to the moderator (see ABC ‘Alert Moderator’ function as an example)
  • Consideration of the level of controversy that may be generated by the consultation subject matter and review moderation arrangements accordingly (i.e. more human moderation of the consultation may be appropriate for sensitive subject matters)

Sample Moderation statement

Posts to this consultation forum may be moderated according to the Acceptable Use Policy. Where a post does not comply with the Acceptable Use Policy it will be removed from the forum. If the person making the post has provided contact details, they may be contacted and informed of the reasons for the removal and invited to resubmit the post after editing so that it complies with the policy.

Risk Assessment

The management of online consultation and the selection of an online consultation approach should be based on a risk assessment, which considers risks around the objective, subject, audience and so on of the relevant consultation. Common risks include

  • Agenda hijack
  • Security threats (denial of service attacks, website defacement attacks, hacking)
  • Threats to participants (identity fraud, access to personal information of participants)
  • Negative publicity in the press and broadcast media
  • Negative sentiment in online communities
  • The consultation may not be accessible to people with disabilities
  • Technical overloads and failures

Measuring and monitoring

It will be important to carefully measure and monitor the responses to online consultation. It is appropriate to provide both quantitative and qualitative measures. To assist in the overall assessment of the consultation some basic metrics should be collected.

Quantitative measures for consideration include:

  • Number of registered users (if registration is required)
  • Number of submissions received
  • Number of links to the consultation
  • Number of external comments (in the press and broadcast media)
  • Number of references in other online publications and fora (news websites, blogs, listservs)
  • Number of submissions published / not published
  • Number of submissions on topic / off topic
  • Number of Google alerts per time period

Depending on the consultation method employed a range of quantitative information may be available to assist measurement.

Qualitative measures for consideration include:

  • Proportion of registered users providing comment or input vs. read only
  • Proportion of submissions published vs. those not published
  • Proportion of submissions on topic vs. off topic
  • Proportion of positive or negative sentiments expressed in submissions
  • Proportion of positive or negative sentiments expressed in press and broadcast media
  • Proportion of positive or negative sentiments expressed in other online publications and fora (news websites, blogs, listservs)
  • Proportion of ‘useful’ submissions to those which are not useful
  • Overall quality of submissions

It will very be important to monitor and record references to and discussions about the consultation which take place on other internet sites. It may be that the consultation will generate significant discussion in other online fora and this can be analysed along with input generated on the government consultation website.

Analysing input

According to the OECD’s Guiding Principles for successful online consultation agencies should ensure they have the time, resources and expertise to provide analysis of the input received via the online consultation. Free text comments like those used in blogs and online forums will require greater human resources than closed or fixed question automatic processing allows, like those used in online surveys. These considerations should be taken into account in the planning stage of the consultation.

Since all online consultation will use a variety of mechanisms and tools agencies should consider:

  • Using data gathering and analysis applications to assist in collecting, compiling and analysing input
  • The use of software applications and web based statistical packages to automatically capture a range of statistics
  • For complex and high traffic consultations, the use of automated text and concept mining tools, web data mining tools and business intelligence software

It should be noted that ICT based text mining is an emerging technology and as yet may offer limited support for evaluation.

Evaluating the online Consultation

The evaluation process will help determine the effectiveness of the online consultation.

Some questions for consideration include:

  • Was the target audience reached?
  • Were the promotion techniques adequate?
  • Were the issues with access or accessibility?
  • Was the volume of responses effectively managed?
  • What was the quality of the submissions? Where they informed by available background material?
  • Was timely feedback provided?
  • What worked well and what could have been done better?
  • Where there any unanticipated outcomes?
  • Did the input of participants contribute to policy development or decision making?

Conclusion

The Government is committed to experimenting with new and emerging online communications channels to enhance citizen engagement and inform policy development. Many agencies are already conducting their own experiments and these Guidelines have been based on liaison with many of these agencies. It is expected that these Interim Guidelines will be further developed and supplemented by other advice and guidance as best practice emerges.