Modern Communications Operating Model 3.0
What you need to build and lead a successful communications team
GCS Strategic Approach GCS Strategy: Performance with Purpose and UK Government Communication Plan |
People and structure |
Team design principles Communication disciplines Working across your organisation Equality, Diversity & Inclusion Building Capability & Talent |
Policies |
Functional Standard: GovS011 Working with GCS (inc. governance) Propriety & ethics Generative AI Procurement and spend (inc AMC) Data handling and protection Accessible communications HMG brand guidelines |
Guidance and tools |
OASIS campaign planning Framework for Ethical Innovation Evaluation Cycle Crisis communications Mis- and disinformation PITCH Behavioural science/COM-B Guidelines for influencer marketing Models for disciplines Media Monitoring Unit |
Introduction: how to use MCOM 3.0
The purpose of this new Modern Communications Operating Model (MCOM) is to provide simplicity and clarity about the expectations of teams and leaders within the Government Communication Service (GCS).
MCOM brings together all the policies and guidance needed to build and lead a team that delivers the GCS vision of exceptional communications that make a difference.
This updated MCOM uses a must*, should, could framework to provide complete clarity on: the policies teams must follow; those that we recommend they should follow; and guidance that is available to consult and apply where needed.
The GCS Strategy and Government Communications Plan set the overarching strategy framework for government communications. The MCOM ‘house’ sits underneath this with three pillars: People & Structure, Policies, and Guidance & Tools.
Whether you are new to GCS, or an established leader who wants an accessible guide to best practice, this MCOM is for you. It is a living document and will be updated regularly, so we welcome ongoing feedback to ensure it remains relevant to you.
We hope that this updated approach enables you to use the recommendations and supporting guidance within MCOM to its best and fullest effect. We look forward to working together to continue delivering world class communications.
*The Communication Functional Standard (GovS011) uses the term Shall for mandatory elements. In this document, for simplicity we use Must rather than Shall.
GCS strategic approach
The GCS Strategy 2022-25 ‘Performance with Purpose’ and the annual Government Communication Plan set out what we deliver. MCOM’s policies and guidance set out how to deliver exceptional communications, develop your people and build great teams.
All departmental or organisational communication plans must reflect the strategic priorities in the Government Communication Plan. The plans must also include clear metrics to support the delivery of the cross-government and organisational objectives, approved by the organisation’s board (or equivalent).
For team leaders:
Strong leadership skills are critical to the successful delivery of effective and efficient government communications. As leaders, Directors and Heads of Communication set the vision for their teams, a vision which must support a shared vision of communications across government. Directors and Heads of Communication are expected to make a corporate contribution to GCS by working on cross-government projects such as the delivery of the Strategy Commitments. The following leadership objective must be included in annual performance and development plans of all SCS leaders:
“GCS SCS to play an active role in championing the three pillars of the GCS Strategy 2022-25 by promoting collaboration, increasing efficiency and innovation, supporting great people and raising professional standards, and contributing to the delivery of the GCS strategy commitments.”
We will support SCS leaders in doing this by setting out clear expectations, a new leadership capability framework (to be launched Autumn 2024) and targeted key skills development to ensure they stay up to date in areas such as the latest trends in technology. Further guidance on Leadership, including the GCS Leadership Framework, is available from Leadership – GCS.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | All departmental or organisational communication plans must reflect the strategic priorities in the Government Communication Plan. | Must |
Leaders | Plans must include clear metrics to support the delivery of the cross-government and organisational objectives, approved by the organisation’s board (or equivalent). | Must |
Leaders | The following leadership objective must be included in annual performance and development plans of all SCS leaders: “GCS SCS to play an active role in championing the three pillars of the GCS Strategy 2022-25 by promoting collaboration; increasing efficiency and innovation; supporting great people and raising professional standards; and contributing to the delivery of the GCS strategy commitments.” | Must |
People and structure
Principles and guidance on setting up, managing and developing a high-performing communication team, including working with the GCS and in/with ALBs.
Directors and Heads of Communication must clearly set out roles and accountabilities (e.g. in an organogram).
Directors and Heads of Communication must take the following principles into account when designing their teams:
- Ensure, through tiered accountability, that it is clear who makes decisions and owns outcomes and processes;
- Work collaboratively in order to achieve clear, simple and consistent communication on behalf of government; manage duplication and minimise complexity;
- Keep processes simple, proportionate and user-focused, and;
- Define roles to suit the needs of the activity being undertaken.
The purpose and size of organisations will differ, but every communications team should apply the common, gold standard principle of using a multi-disciplinary approach when structuring their teams.
Every communication team should have the core seven MCOM disciplines represented to differing degrees depending on organisational need, size and focus. This does not mean needing seven separate siloed teams. In the spirit of a multi-disciplinary approach, it means having those skills somewhere in the team and available to others.
New design principles for Digital content teams have been developed to reflect the creation of Digital as a new discipline. Guidance on the design principles for Media, Strategic Communications, External Affairs, Internal Comms and Marketing are available from the GCS website.
Design principles for Data & Insight will be launched in Autumn 2024.
Digital team design principles
Digital teams should include generalist digital experts with a deep understanding of the digital channels, platforms and content formats required to grow and engage audiences, as well as specialists in the fields of digital content creation and data analytics.
There are four core functions of a modern digital communications team around which your digital team should be structured:
- Digital Strategy & Leadership
- Data and insight analysis
- Technical content creation including these specialisms: Graphic design and animation; Videography; Photography
- Copywriting, editing, channel management & strategic platform publishing, including all digital channels.
The full Digital discipline guide is available from the GCS website.
</blockquote class=”wp-block-quote”>The case study below outlines how a small organisation has structured their communications team in a multi-disciplinary way. Further case studies will be added to illustrate key principles and help leaders think about how they could shape their own teams.
Structuring a small team: the Scotland Office:
- Smaller departments offer a good opportunity for strong cross-functional agile working, skills development and collaboration.
- Each member of the team will have their identified specialism, alongside being upskilled on basics such as social media management, ministerial visit logistics and managing incoming media enquiries. This allows work to flow to peaks and a fairer balance across a very small team. It also helps to ensure that everyone has an appreciation of the wider strategy, context and positioning of Scotland Office communications.
- This does not mean everyone does some press work or social media engagement; people’s specialisms are respected and the team’s broader, practitioner level skills are developed.
</blockquote class=”wp-block-quote”>
For Requirement Must/Should/Could Leaders Directors and Heads of Communication must clearly set out roles and accountabilities (e.g. in an organogram). Must Leaders Directors and Heads of Communication must take the following principles into account when designing their teams: Tiered accountability;
working collaboratively; managing duplication and minimising complexity; keeping processes user-focused; defining roles to suit the needs of the activity.Must Leaders Communication teams should consider how to represent the seven MCOM disciplines, depending on organisational need, size and focus. Should Leaders Digital teams should reflect the four core functions identified in the GCS design principles. Should
There are seven MCOM communication disciplines: Data & Insight, Digital, External Affairs, Internal Communication, Media, Marketing, Strategic Communication.
Each discipline has a cross-government Head of Discipline (HoD) and Deputy Head of Discipline (DHoD) who are expected to spend 20% of their time developing their discipline’s network, building capability, sharing best practice, facilitating cross-government collaboration and raising standards. They are appointed through a light touch open recruitment process, and are in post for two years.
For team leaders:
Directors and Heads of Communication should support the HoDs and DHoDs and enable them to include their 20% contribution within their Personal Development Plans (PDPs). DoCs and HoCs should work collaboratively with the discipline networks.
The Heads and Deputy Heads of Discipline are:
- Data & Insight – Pamela Bremner, Home Office (HoD)
- Digital – Ed Bearryman, No 10 (HoD) and Zara Farrar, HMT (DHoD)
- External Affairs – Kate Whitty-Johnson, Department for Levelling Up, Housing and Communities (HoD), Samantha Abrams, Ministry of Justice and Davina Collison, Department for Levelling Up, Housing and Communities (DHoDs)
- Internal Communications – Russell Grossman, Office for Rail and Road (HoD) and Sara Vogt, Ministry of Justice (DHoD)
- Marketing – Chloe Saklow, Department for Education (HoD) and Jo Parry, ONS (DHoD)
- Media – Andrew Darby, Department for Education (HoD) and Fiona Richards, DfT (DHoD)
- Strategic Communications – Sarah Clark, DCMS (HoD) and Gemma Taylor, HMT, (DHoD)
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communication should support the HoDs and DHoDs by including their 20% contribution within their PDPs. DoCs and HoCs should work collaboratively with the discipline networks. | Should |
Directors or Heads of Communication are responsible for managing the communication function (all communications work, not just the comms team itself) for your organisation. They are accountable for ensuring their whole organisation, including ALBs and embedded communicators, complies with the Functional Standard GovS011: Communication. They are also accountable for their whole organisation aligning to the vision and strategies of GCS, and for building their professional communications capability and skills.
Directors and Heads of Communication should have oversight of relevant recruitment across their whole organisation, including embedded communicators and sponsored ALBs. For example, this would include agreeing job descriptions and participating in selection panels.
This section contains the principles which Directors and Heads of Communication should follow to establish collaborative partnerships between ALBs and sponsoring departments.
A helpful overview of how ALBs should link to Directors of Communication and the Head of Profession can be found in the overall Government Functional Standard – GovS 001 (figure 6 on page 17).
Effective working between ALBs and Sponsor Departments
The principles in the ALB/Sponsor department working guidance set out how Directors and Heads of Communication should approach building strong links between ALBs and Sponsor departments, namely:
- Where an organisation is part of an ALB cluster, duplication should be removed, and closer, integrated working should be the norm.
- Organisations do not necessarily need every capability in-house, and should look at sharing service opportunities across a group, or across the GCS.
- Sponsor departments should make sure the right processes are in place to quality assure all ALBs – without inhibiting ALB autonomy and expertise – and encourage and enable access to the GCS learning offer.
Sensible collaboration doesn’t preclude operational independence. It means coming together where there are shared interests without limiting the ability to pursue individual responsibilities.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Use the ALB/Department principles to build links between ALBs and their sponsor departments. | Should |
Working with embedded communicators
Many organisations across government will have ‘embedded’ communications teams or staff working outside the core communications function. Directors and Heads of Communications should establish links and reporting lines that foster strong collaboration and oversight, as well as ensuring embedded communicators are delivering high quality communications work consistent with GCS and organisational standards, and have access to career and skills development and learning.
As a starting point, a Director or Head of Communication should know how many embedded professional communicators work within their organisation, what communications work they are undertaking and the level of communication skills.
As a starting point, a Director or Head of Communication should know how many embedded professional communicators work within their organisation, what communications work they are undertaking and the level of communication skills. Directors and Heads of Communication should have the same commitment to upskilling all communicators in their organisations, and direct them towards the guidance and skills training provided by GCS. Civil servants looking to recruit embedded roles should seek approval from their Director or Head of Communication before recruitment to check that the relevant activity cannot be supported by the central team and to avoid duplication.
Directors and Heads of Communication should read and adopt the principles for working with embedded communicators and reflect the learning from within the case study from DfE, where relevant. These will help to foster greater collaboration and enable you to fulfil the obligations set out in GovS001.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Ensure they know how many embedded professional communicators work within their organisation, what communications work they are undertaking and the level of communication skills/development needed. | Should |
Leaders | Directors and Heads of Communication should read and adopt the principles for working with Embedded Communicators | Should |
Increasing diversity of thinking and representation is critical to our operational success. We cannot communicate effectively with people across the UK unless we draw our talent from every section of society. We want GCS to be an open and inclusive environment where people know that different views, backgrounds and experiences are welcome. We want to create careers across the UK and our ambitious GCS Location Strategy sets out plans to help people build careers and progress to senior positions in regions across the UK.
EDI Action Plan
The GCS Equality, Diversity and Inclusivity (EDI) Action Plan sets out the actions that we all should take to improve our diversity and inclusion, building and developing diverse teams across the UK so that we can communicate effectively with the communities we serve.
The EDI action plan applies the Civil Service Diversity & Inclusion Strategy to our communication profession and outlines clear actions for how we will deliver our objectives.
For team leaders:
EDI is the foundation for thriving individuals, innovative teams and impactful communication. As a Director or Head of Communication you should review the EDI Action Plan and align it with your own people plans, ensuring you have plans in place to deliver the short, medium and long term actions detailed in the report.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Review the EDI Action Plan and align it with your own people plans, ensuring you have plans in place to deliver the short, medium and long term actions detailed in the report. | Should |
Location Strategy
For team leaders:
You should consider and incorporate the GCS Location Strategy 2023-25. All Directors and Heads of Communication should promote and support careers across the UK by advertising GCS roles outside of London by default, and actively work to ensure that team members across all sites work collaboratively and feel part of the GCS Community, with access to training, development and career opportunities.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Promote and support careers across the UK through advertising GCS roles outside of London by default and across networks. | Should |
Leaders | Consider and incorporate GCS current best practice on location strategy and team building. | Should |
Workforce planning
For team leaders:
The GCS Data Collection takes place annually and collects data for all 300 organisations within GCS to help with workforce planning and skills development. All Directors and Heads of Communication should provide support in returning data for all the organisations they lead. You should nominate representatives to ensure Sponsored Organisations within your departments are providing the information in a timely and complete way.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Ensure your organisation completes and returns the annual GCS Data Collection | Should |
Leaders | Nominate representatives to ensure Sponsored Organisations within your departments are providing the information in a timely and complete way. | Should |
Our aspiration is for GCS to be a destination of choice for communications professionals. We aim to attract, recruit and retain the best communications talent by providing world class training and development programmes, and reinforce a culture of continuous improvement and excellence by investing in the skills we need.
Our updated Career Pathway provides clarity on how to progress, alongside the new GCS Advance programme which provides outstanding learning across all disciplines and levels of expertise, to develop the skills we need now, and in the future.
Directors and Heads of Communication must take responsibility for building capability and talent within their organisations. They must ensure that learning and development is conducted in line with the results of analysis of capability and learning needs on both an organisational level, and by contributing to the annual GCS Data Collection.
Directors and Heads of Communication should actively encourage their teams to use the Career Framework to provide clarity on the skills, capability and experience needed by grade to progress in their career. Communicators should use the Career Framework to discuss learning and development requirements and future career goals, and record these in PDPs.
Directors and Heads of Communication must actively identify talent within their organisations, complete talent grids and champion the GCS talent approach. Senior leaders should use the GCS Apprenticeship programme to attract diverse, external early talent and the GCS Advance Leader offer to foster an exceptional cadre of internal GCS leaders.
For | Requirement | Must/Should/Could |
---|---|---|
All | Communicators should use the GCS Careers Framework to discuss future career goals and learning requirements, and record these in PDPs. | Should |
Leaders | Directors and Heads of Communication should actively encourage their teams to use the Career Framework to provide clarity on the skills, capability and experience needed by grade to progress in their career. | Should |
Leaders | Directors and Heads of Communication should actively identify talent within their organisations, complete talent grids and champion the GCS talent schemes on offer. | Should |
Learning and development
All members of GCS must engage in 4 to 5 days of training across the year (worth at least 30 Continuing Professional Development points) and have this reflected in their PDPs and GCS Connect profiles. Directors and Heads of Communication should drive awareness of and champion the new GCS Advance offer within their organisation. In addition, Directors and Heads of Communication should help to change the culture around learning and development, and ensure more space is created to prioritise L&D.
For | Requirement | Must/Should/Could |
---|---|---|
All | All members of GCS must engage in 4-5 days of training across the year (worth at least 30 Continuing Professional Development points) and have this reflected in their PDPs. | Must |
Leaders | Directors and Heads of Communication should drive awareness of and champion the new GCS Advance offer within their organisation | Should |
Policies
This section will set out mandatory policies relating to government communication.
Functional standards support the effectiveness and efficiency of work in government (Communication is a function, as is HR, Digital, Finance etc). They are cross-government, agreed by the Civil Service Board and promoted and embedded by the individual functions.
The Functional Standard for Communication, GovS011 sets the expectations for the management and practice of government communication.
This short video provides a useful introduction to Functional Standards, what they do and how they can help: Government Functional Standards explained
Directors and Heads of Communication must have a plan in place to demonstrate they are complying with the Communications Functional Standard’s mandatory elements (the ‘shalls’) in line with their business needs and priorities. This was set out in the Dear Accounting Officer letter dated 20 September 2021, which set out that use of the standards should be embedded into each organisation’s business plans. Statements about use of functional standards should be included in annual reports and, where relevant, Accounting Officer system statements.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communication must have a plan in place to demonstrate they are complying with the Communications Functional Standard’s mandatory elements (the ‘shalls’) in a way that meets their business needs and priorities. | Must |
Leaders | Use of the standards should be embedded into each organisation’s business plans. Statements about use of functional standards should be included in annual reports and, where relevant, Accounting Officer system statements. | Should |
The Government Communication Service is accountable to the Ministers at the Cabinet Office. The Minister reviews performance against the delivery of the Government Communication Plan, which Directors and Heads of Communication must support the delivery of through their organisation’s annual communication plans.
Directors of Communication and Heads of Communications for ALBs play a key role within the GCS Governance structure, sitting on two cross-government boards which feed into the GCS Board. These boards provide collective responsibility for planning, supporting informed decision-making and driving improved efficiencies across government. All Directors of Communication should actively participate in these boards and make corporate contributions to the successful delivery of GCS Strategy Commitments and the cross-government working groups.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | All Directors of Communication should actively participate in the relevant boards and make corporate contributions to the successful delivery of GCS Strategy Commitments and the cross-government working groups. | Should |
Like all civil servants, government communicators must carry out their work objectively and without political bias, in accordance with the standards of behaviour and ethics set out in the Civil Service Code. As set out in GovS011, Directors and Heads of Communication must ensure that all communications uphold public service codes of conduct.
Directors and Heads of Communications must ensure that all Government communicators are clear on propriety and ethics guidance, their responsibilities and how they raise a concern. Detailed guidance on propriety can be found on the GCS website.
Directors and Heads of Communications must ensure that all those within their organisation are fully aware and regularly reminded of their duties and obligations as civil servants and government communicators. Propriety and ethics training is available from GCS and helps communicators understand how to apply the guidance to their work using real-life case studies and advice from GCS leaders. The training is mandatory for those working in government departments and strongly advised for those working in ALBs. Information on how to raise a concern is available now.
Directors and Heads of Communication must also follow and share guidance on propriety in digital and social media, emphasising the need for civil servants to adhere to the Civil Service Code as much online as offline.
Policy on the ethical use of new technology, including a decision-making framework, will be launched in March 2024 by the GCS Data & Insight team to complement the digital propriety guidance.
For | Requirement | Must/Should/Could |
---|---|---|
All | Be aware of, and comply with, the standards of behaviour set out in the Civil Service Code | Must |
All | Complete all mandatory training on propriety and ethics. | Must |
Leaders | Directors and Heads of Communications must ensure that all Government communicators are clear on propriety and ethics guidance, their responsibilities and how they raise a concern. | Must |
Leaders | Directors and Heads of Communication must also follow and share guidance on propriety in digital and social media, emphasising the need for civil servants to adhere to the Civil Service Code as much online as offline. | Must |
Leaders | Directors and Heads of Communications should ensure that all communicators within their organisation are fully aware and regularly reminded of their duties and obligations as civil servants and government communicators. | Must |
Generative Artificial Intelligence (AI) is a specialised form of AI that can interpret and generate high-quality outputs including text and images; opening up the potential for opportunities for organisations, including delivering efficiency savings or developing new language capability.
The GCS generative AI policy aims to set the standard for excellence in government communication in the AI age, a period of rapid and exciting technological changes, which offers huge potential in the way we communicate with our audiences. The policy has been developed to support teams in harnessing the benefits of generative AI for the public, and to do this in a responsible way which aligns with our values and inspires trust and confidence in government.
All GCS members using generative AI in their roles must do so in accordance with the latest government guidance. Both the GCS generative AI policy and GCS Framework for Ethical Innovation adhere to key government guidance and help to put these in context of the work we do as government communicators. This includes the Generative AI framework for HM Government, the Introduction to AI Assurance, and further information on these policies can be found under Annex A of the GCS generative AI policy. Members should refer to the government-wide guidance as necessary, alongside guidance from GCS.
Particular care must be taken in ensuring accuracy, inclusivity and mitigating biases. The central GCS team will provide training through GCS Advance to support the responsible use of generative AI and provide guidance on meeting these challenges, which all government communicators should complete.
For | Requirement | Must/Should/Could |
---|---|---|
All | Directors and Heads of Communication must ensure that their teams have read and follow the principles and guidance set out in the GCS generative AI policy. | Must |
All | Directors and Heads of Communication must ensure that the use of generative AI is always done so in accordance with the latest government guidance. | Must |
All | Directors and Heads of Communication should ensure that their teams complete GCS training on AI before using generative AI in their communications work. | Should |
GCS works with all central government organisations to ensure that where taxpayers’ money is being spent on government communications it is cost-effective. Directors and Heads of Communications must ensure that GCS policies on procurement and spending controls are adhered to and understood within your organisation.
Spending controls
The Cabinet Office spending controls cover advertising, marketing and communications (AMC) spend, and apply to campaigns, projects or programmes with planned communications expenditure of £100,000 or more within a financial year.
There is a clear simplified three-stage approval process which must be followed. Details on how to follow the process, along with the technical case form and GCS contacts are available from the GCS website. GCS works to a 21 calendar day SLA from the day the technical business case is submitted. The SLA does not apply during recess. Campaign leaders should ensure that this is built into campaign lead times.
Procurement
Directors and Heads of Communication must use approved government frameworks for the purchasing of external advertising, marketing and communication services and support, and any guidance issued by the Commercial Director within your organisation.
Guidance on buying communication support can be found on the GCS website.
Managing risk – SAFE
The SAFE Framework sets the standard for digital brand safety in HM Government advertising, following the four principles: safety and suitability, ads context, freedom of speech and ethics and enforcement.
Directors and Heads of Communication must ensure that Campaign Team leads are using the SAFE Framework to assess digital environments and adopt a risk-based approach. Using this framework will help GCS to demonstrate responsible use of taxpayers’ money and ensure the UKG brand is protected.
Full guidance on the SAFE Framework and how to complete a SAFE assessment is available on the GCS website.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communications must ensure that GCS policies on procurement and spending controls are adhered to and understood within your organisation. | Must |
Leaders | Directors and Heads of Communication must use approved government frameworks for the purchasing of external advertising, marketing and communication services and support. | Must |
Leaders | Directors and Heads of Communication must also refer to guidance issued by the Commercial Director within their organisation. | Must |
Leaders | Directors and Heads of Communication must ensure that Campaign Team leads are using the SAFE Framework to assess digital environments, and adopt a risk-based approach to government advertising. | Must |
The day-to-day work of government communicators must be understood in the wider context of the legislative and regulatory environment. Whilst innovation in technology provides huge opportunities for government communication, it is accompanied by significant ethical and legal considerations around data handling and data protection which all government communicators must have awareness of.
Directors and Heads of Communication must ensure that the work of their communications team conforms to the principles of the Data Protection Act 2018. This act controls how personal information is used by organisations, businesses and government, and every government communicator must have an understanding of the eight data protection principles. This includes when it is necessary to complete a Data Protection Impact Assessment (DPIA). Please refer to ICO guidance on when this is required.
In summary, personal data should be:
- Processed fairly and lawfully and not unless certain conditions are met
- Obtained for specific and lawful purposes and not further processed in a manner incompatible with that purpose
- Adequate, relevant and not excessive for that purpose
- Accurate and, where necessary, kept up to date
- Processed in accordance with the rights of the individual
- Kept no longer than is necessary for the purpose
- Protected by appropriate security
- Not transferred without adequate protection.
You should refer to your organisation’s Data Protection Officer to ensure compliance, get approval on wording relating to Data Protection and for further guidance.
Directors and Heads of Communication must be aware of the introduction of the General Data Protection Regulation (GDPR) in the Data Protection Act 2018, and ensure compliance when planning and implementing government campaigns. Put simply, ‘privacy by design’ must be a key objective.
The Information Commissioner’s Office website provides comprehensive information on the Data Protection Act and GDPR and you should refer to your Data Protection Officer for further guidance.
Alongside Data Protection principles which all government communicators must know is more specialist guidance which Directors and Heads of Communication must be aware of concerning data protection and Direct Marketing, Campaign Platform development, Programmatic Real Time Bidding, and Facebook related privacy notices and cookie banners:
GDPR and Direct Marketing
The majority of communications from government to individuals are unlikely to constitute direct marketing. However, campaign teams must demonstrate a lawful basis for processing personal data under UK GDPR within their Data Protection Impact Assessment (DPIA) if they are planning to reach audiences through this approach. Further guidance is available from the GCS website – ICO Direct Marketing campaign guidance and from the Information Commissioner Officer’s website – Compliant use of Direct Marketing approaches. Campaign leads should consult their organisation’s Data Protection Officer.
Data Protection and Data Management guidance in Social Media Campaigns and website development
Guidance on ensuring compliance with GDPR when building campaign platforms must be consulted – GCS website development GDPR guidance
Departments must adopt a ‘Least Data by Default’ approach when using programmatic real-time bidding advertising (RTB) to deliver digital media. This guidance provides the practical steps departments must take to ensure compliant use of RTB – Compliant use of Programmatic Real-Time-Bidding
Guidance on Facebook-related privacy notices and cookie banners must be followed by those who work on and deliver government campaigns that use Facebook’s advertising products and involve sharing data with Facebook.
Coming soon:
In March 2024, GCS will publish guidance under the Innovation & Data strategy on the ethical use of new technology, including a new ethical decision-making framework for members to harness new tech like generative AI.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communication must ensure that everyone in their communication function is aware of their responsibilities under the Data Protection Act. | Must |
Leaders | Campaign leads should refer to their organisation’s Data Protection Officer (DPO) for approval on wording relating to Data Protection as well as advice on compliance with the DPA. | Should |
Leaders | Directors and Heads of Communications must understand and comply with GDPR legislation when planning and implementing government communication campaigns. | Must |
The Equality Act 2010 requires the government to make reasonable adjustments to ensure that everyone has equal access to information, goods and services. If your communication is about something that will affect disabled people, or they are entitled to know or be included in, you must ensure that you have done as much as can be reasonably expected to ensure they can access and respond to the information. Please refer to the GCS guidance on accessible and inclusive communications.
GCS has set out accessibility standards which all GCS communications content should meet. The standards also help you to think through how you can make your content inclusive to different audiences, so that it has a wider and more effective impact.
In 2022, the British Sign Language (BSL) Act became law, meaning that British Sign Language (BSL) is a recognised language of the UK. The BSL Act requires ministerial departments to report on their use and promotion of BSL in public announcements on policy or changes to the law. There is no statutory requirement for all government communications to be translated into BSL. But, all government departments should consider where the use of BSL will be of most interest and importance to Deaf BSL users.
GCS has published guidance to support government communicators, policy officials and others to provide BSL content to those who need it.
For | Requirement | Must/Should/Could |
---|---|---|
All | Read the Accessible Communications guidance on the GCS website and ensure all government communications are compliant. | Must |
It is important for the public to easily recognise the work of government, departments, agencies and Arms Length Bodies. This shows the information is official and comes from the government.
The unifying element of the Government identity is the Royal Coat of Arms. Only departments of His Majesty’s Government (HMG) and its organisations are permitted to use the Royal Coat of Arms and associated insignia.Directors and Heads of Communication must ensure that all communication activities comply with HMG Government identity guidelines, as set out in the Branding guidance on the GCS website.
Guidance & tools
This section sets out guidance and tried-and-tested tools for delivering best in class communication activity.
A campaign is a planned sequence of communications and interactions that uses a compelling narrative over time to deliver a defined and measurable outcome.
All government communications should be viewed in the context of a wider campaign, for example, what do we want to achieve and what is the strategic context? This way we can ensure that all our work links to a clear objective and we can evaluate the impact of everything we do.
All government communication campaigns should be developed and delivered according to the principles set out in the Guide to campaign planning: OASIS
For | Requirement | Must/Should/Could |
---|---|---|
All | All government communication campaigns should be developed and delivered according to OASIS principles. | Should |
The Framework for Ethical Innovation has been established to guide government communicators on the ethical and proper use of emerging technologies and applications of data. It is designed to enable us to identify what we should be considering from the outset of our innovative work, by using our Civil Service and GCS values to help inform and make the best decisions possible, including considerations around data protection, security and privacy.
Providing a step by step approach, it sets out the safeguards we all need to adopt to assess innovative new approaches, providing government communicators with the confidence that their approach meets the Civil Service Code,GCS Code of Conduct (also referred to as the ‘Guiding Principles, and topic specific policies and frameworks (e.g. the HMG Generative AI Framework, guidance published by the Responsible Technology Adoption Unit, GCS Generative AI policy, GCS Innovating with Impact Strategy and the GCS SAFE Framework.
For | Requirement | Must/Should/Could |
---|---|---|
All | Directors and Heads of Communications ensure that their teams have read and apply the framework to any innovation projects they are scoping. | Must |
All | Directors and Heads of Communications be aware of the range of cross-government policies and frameworks which sit alongside this Framework published by GCS. | Must |
All | Directors and Heads of Communications be clear on the process for raising concerns, and what to do if barriers are identified which prevent the upholding of legal obligations, propriety guidance, or best practices and policies. | Should |
Evaluation is the cornerstone of effective communication, enabling communicators to reach target audiences effectively and do so in a meaningful and cost-effective way. It should be seen as a continuous process that fuels ongoing learning and development, supporting us all in making informed decisions which are fuelled by evidence and insight. Evaluation should be seen as an intrinsic element of the communications planning process from the very outset, with activities built into each campaign stage so learning can be incorporated and reflected in real-time, as well as to improve future activities.
Building on the foundations set out by the Evaluation Framework 2.0, the new Evaluation Cycle sets out a six-step process to support communicators in meaningfully measuring the impact of their work. The Cycle brings together the latest best practice guidance and thinking on evaluation, including digital techniques which enable real-time evaluation. It also reflects changing audience demographics and is rooted in principles of inclusivity. It is designed to be an agile framework, flexible enough to be used for all types of communications, from low cost/no cost activities to larger-scale paid-for campaigns. The Evaluation Cycle document clearly maps out the connections with OASIS, COM-B and the Theory of Change, enabling communicators to take an integrated, holistic approach when planning activities.
For | Requirement | Must/Should/Could |
---|---|---|
All | Directors and Heads of Communications should ensure that all those working within their teams implement the principles and processes set out in the Evaluation Cycle. | Should |
All | Directors and Heads of Communications should emphasise the need for continuous learning and innovation, and create the right environment for this to happen i.e. learning from what does and doesn’t work. They should ensure that insights and learning are shared across teams, government organisations and GCS. | Should |
All | Directors and Heads of Communications should draw attention to the new elements of the cycle and the links with OASIS, COM-B and the Theory of Change. | Should |
Effective communication is a vital component of good crisis management.
As set out in Crisis communication: A behavioural approach, during a crisis government communicators must act quickly to ensure the public has access to accurate information, knows the actions and behaviours they can adopt to protect themselves and others, and understands what the government is doing and why.
Directors of Communication must be responsible for preparing and managing crisis communications associated with the risks that their department owns and is the ‘Lead Government Department’ for (as identified in the National Security Risk Assessment). The GCS Crisis Team will support departments to develop robust communication contingency plans in place before a crisis, and ensure they have the right capabilities in place to implement that plan.
The Crisis Communications Operating Model sets out what the communication function must do to prepare, respond and recover from crisis situations. It aims to:
- Clarify roles and responsibilities
- Embed comms into crisis management & preparedness structures
- Grow a crisis comms community and help us work together
- Remove operational barriers
- Build our crisis comms expertise
- Keep up to date with the latest lessons
Directors of Communication must ensure they are familiar with the Crisis Communications Operating Model
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors of Communication must ensure they are familiar with the Crisis Communications Operating Model. | Must |
Protecting the UK’s prosperity, security and democracy is the first duty of the British government. Our communication must always be underpinned by this mission, supporting our allies and partners, and deterring our adversaries. This requires developing and leveraging our soft power and encouraging the world to invest, partner and work with our country.
It also means developing a clear eyed understanding of how disinformation is deployed by our adversaries, and developing expertise on how to counter these techniques.
Directors and Heads of Communications should refer to the RESIST 2 Counter Disinformation Toolkit for guidance on how to reduce the impact of mis- and disinformation.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communications should refer to the RESIST 2 Counter Disinformation Toolkit for guidance on how to reduce the impact of mis- and disinformation. | Should |
Modern communication is borderless and vital to influencing and shaping perceptions among global audiences. If the UK is to be successful in achieving its international goals, it needs to fully use its strategic communication capabilities in terms of allies, assets and abilities. The guidance and approach contained within the PITCH toolkit will enable you to develop and deliver effective global communication campaigns which are credible, proactive and effective, and which cut through a crowded information environment. The PITCH framework is centred on: working in partnership; using insight; gathering trusted voices; delivering compelling content; and maintaining the highest ethical standards, in line with our democratic values.
All Directors and Heads of Communications working with international audiences should be familiar with the tools and best practices set out within PITCH, and share them proactively with their teams. PITCH should be read in tandem with the RESIST 2 Counter disinformation toolkit as it builds on the ‘Strategic Communications’ step of RESIST. You should refer to the PITCH checklist contained within Annex A to the guidance when developing your international campaigns.
PITCH should be read in tandem with the RESIST 2 Counter disinformation toolkit.
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | All Directors and Heads of Communications working with international audiences should be familiar with the tools and best practices contained within PITCH and share them proactively with their teams. | Should |
Behaviour change is one of the primary functions of government communication – helping change and save lives, helping the government run more effectively and saving taxpayers’ money.
Directors and Heads of Communication should ensure they are familiar with GCS guidance on adopting a behavioural approach, the EAST framework and the COM-B model, to ensure communications are audience-centred and effective.
The EAST framework was devised by the Behavioural Insights Team and provides an easy to-use checklist based around four key principles – making communications Easy, Attractive, Social and Timely. Each element of the framework is designed around well-established behavioural theory principles.
The COM-B (Capability, Opportunity, Motivation, Behaviour) model helps identify the barriers to behaviour change in a systematic and effective way.
References
The Principles of Behaviour Change Communications – GCS
Strategic Communications: a behavioural approach – GCS
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communication should ensure they are familiar with GCS guidance on adopting a behavioural approach, the EAST framework and the COM-B model, to ensure communications are audience-centred and effective. | Should |
Influencer Marketing is when brands partner with individuals who have an engaged online following. This includes social media influencers, podcasters and professional experts. It can be an effective way to reach audiences that the Government and traditional marketing channels find hard to reach. When used in a transparent way, influencers can create personalised and engaging content for your campaign.
However, if used incorrectly, public confidence in government communications risks being eroded. Therefore, all government communicators should read and follow the guidance set out in the GCS guidelines for influencer marketing (GCS members only).
All government communicators considering using influencers as part of a campaign should understand the need for rigorous checks to take place before an activity goes live. This is to ensure any partnership does not represent a reputational risk to the Government. As per the Regulation of Investigatory Powers Act 2000 (RIPA), these checks should be managed by an agency. The principles set out in the SAFE Framework should also be used as a guide.
Government communicators should refer to their organisation’s guidelines on Influencer Marketing.
For | Requirement | Must/Should/Could |
---|---|---|
All | Government communicators should ensure that rigorous checks take place, following the SAFE Framework principles, before an activity goes live. | Should |
Each of the seven MCOM disciplines provides guidance around key skills and/or areas of practice.
Directors and Heads of Communication should follow these according to the needs of their organisation (see Team-building principles, above).
- External affairs
- Marketing
- Internal communication
- Media
- Strategic communication
- Data & Insight (full Data guidance to follow)
- Digital communication
For | Requirement | Must/Should/Could |
---|---|---|
Leaders | Directors and Heads of Communication should follow GCS disciplines guidance and best practice according to the needs of their organisation | Should |
The Media Monitoring Unit (MMU) is a 24/7 service which provides briefings on Government issues from the day’s print, digital and broadcast media, delivered on a subscription basis with departments and ALBs paying an annual fee.
MMU also provides verbatim transcripts and access to embargoed stories, as well as ad hoc requests for interview and report summaries from subscribing departments. For any monitoring requests or enquiries please contact mmu@cabinetoffice.gov.uk