Food Standards Agency - Communication Capability Review Management Summary Private
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OFFICIAL
Food Standards Agency
Communication Capability Review
Management Summary
Private
Date: 20 March 2015
Version: 2nd draft
Prepared by: Policy & Capability team, Prime
Minister’s Office & Cabinet Office
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1. Management summary
Background
1.1. The Communication Capability Review of the Food Standards Agency is one of a series of
reviews across Whitehall departments and Arms Length Bodies. The review fieldwork took
place in November/December 2014.
1.2. Each review is carried out by a combination of peer and external reviewers; this review was
conducted by Nick Wright, Director of Communications at BDO, Graeme McEwan Group
Director of Communications and Brand at Standard Life, Miles Celic, Group Director of
Strategic Communications at Prudential and Clare Jennings, Deputy Director of
Communications at Department for Environment, Food and Rural Affairs (Defra). The
review methodology is based on interviews, workshops and examination of supplied
materials. The reviewers evaluate capability against business requirements using a
framework. This report contains their qualitative assessment of capability and provides
recommendations for improvement.
1.3. Communication is a pan-organisational responsibility. The review’s scope covered the
breadth of the Food Standards Agency external and internal communication, including but
not limited to that undertaken by its communications division.
1.4. The review team interviewed around 40 people in a combination of interviews and
workshops. Interviewees included the Food Standards Agency’s communications staff, ten
senior staff/directors and key stakeholders such as the British Retail Consortium, the
Department of Health and Which?
Organisational context
Detail organisational / leadership changes, issues, challenges
1.5 The Food Standards Agency is a non-ministerial department, employing circa 1,200 staff
with a turnover of around £90m. Its primary responsibilities are set out in the Food
Standards Act of 1999 which defines its regulatory responsibilities and its duty to protect
the interests of consumers. In 2010, the Coalition Government returned some of its
policy responsibilities (e.g., health and nutrition, food labelling) back to Whitehall
departments and it is acknowledged internally and externally that this had a considerable
impact on the FSA. The policy areas it lost responsibility for had formed the bedrock of
much of the organisation’s communications effort and the overall reduction in size and
responsibilities affected the organisation’s confidence and sense of purpose.
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1.6.1 The FSA operates in a complex political and delivery landscape; having to manage
relationships and accountability across Whitehall, the three devolved administrations of
the UK and all local authorities. Like most public sector organisations it faces ongoing
financial challenges and some uncertainty over its future. A striking challenge facing the
FSA is the strategic tensions that pull on the organisation. Examples include the potential
for conflict between its status as an independent non-ministerial department and being
part of the government, the tension between its role as a regulator and a consumer
champion, and between its scientific approach and its ambition to become more message
and campaign led. These debates were raised throughout the review, both internally and
externally. And whilst none of these questions require simple yes or no answers, they
require that the FSA is constantly making finely-tuned judgements and choices.
1.5. There is new leadership and a recently published new strategy which taken together have
freshly defined the role of the FSA. This has had a tangibly positive effect internally.
Engagement scores are showing signs of improvement and in the course of our interviews
is was evident that the strategy had returned a clarity of purpose. Communications is at the
very heart of the strategy and this presents a huge opportunity. If this ambition is to be
realised, a robust communications strategy now needs to be developed.
Findings
Summary
1.8. The communications team is highly regarded and the Director of Communication is
operating well as an influential leader in the organisation.
1.9. The leadership of the organisation believe in the power of communications, and
recognise the huge power it can have in extending the reach of a regulator; the Board and
Chief Executive are demanding strategic customers and are ambitious for what
communications can achieve.
1.10. The communications team are delivering notable and award-winning campaigns, there
are pockets of excellence (digital) and a commitment to deepen their expertise and
capability in behaviour change marketing. They play a multi-faceted role in:
Leading communications policy and strategy and delivering agreed ‘corporate’
responsibilities
Responding to the needs of internal clients
Facilitating best practice across the organisation e.g. social media expertise
1.11. For the communications function to now sustain this success and indeed go further and
meet the challenge it has been set by the FSA’s overall strategy a more intellectually
robust communications strategy is needed; one that will provide an evidence based
articulation of the principles and choices that will inform where communication attention
and resources will be invested. This should be underpinned by specific and measurable
communications objectives and more evidence of long term planning and evaluation.
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Without this, there is a significant risk that the communications team will not deliver the
impact and outcomes that the organisation requires. Allied to this, deeper and more
targeted consumer insight is also needed in order that communications can make
evidence-based choices about it the audiences and campaign topics it will pursue.
1.12. Capability in internal communications leadership is good; the reviewers think the
structure should reflect the importance of internal communications (the internal
communications lead was of a more junior grade than the marketing and external leads)
and that the organisation could be a more ‘intelligent customer’ of internal
communications; with the same strategic ambition for its internal communications as it
has for its external communications.
1.13. Stakeholder relations is in need of more attention. The reviewers spoke to some
dissatisfied yet significant stakeholders. The organisation is becoming more outcome
focused and as a consequence is ‘tougher’ with elements of its stakeholder base in order
to drive these outcomes. The panel understood this position and recognised the power of
a more adversarial approach when required. However, our view is that this should not be
the primary modus operandi of a regulator (notwithstanding its consumer
responsibilities) A more visible, sustained and strategic approach to stakeholder relations
will support the organisation is building long term, effective stakeholder relationships.
Further, throughout the review stakeholders expressed frustration with their experiences
of having to deal with multiple contacts across a number of Government departments
and agencies on single subject matters and, in some cases, they were not always sure
where responsibilities rest. Whilst this is not solely an FSA issue, the communications
team can play a strong enabling role here. Part of ensuring effective relationships with
stakeholders is to ensure that the relationships are in good repair, proactive and not
transactional. It was the review teams view that the communications team should be
bringing into the FSA regular stakeholder analysis and examples of good practice so that
the organisation overall can improve in this regard. We would also encourage
consideration of the development of some joined up and cross departmental solutions to
stakeholder management.
Positives
Strategy and planning
1.14. Communications plays a pivotal role in the organisation, it is central to the FSA’s future
strategy and the Chair and Chief Executive have considerable ambition for what
communications can achieve. Further, the Director of Communications has earned a
strong reputation and is recognised at senior levels as an effective communications
leader.
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1.15. The importance of planning is recognised and there is strong evidence of tactical and
campaign plans that achieve results.
People and resources
1.16. The communications function has undergone a restructure and has emerged more
effective and more engaged. The review team understood that previous restructures had
given rise to dissatisfaction (and we would encourage the leadership to keep these
lessons in mind) but this legacy was now largely overcome. The team now have a strong
sense of purpose and pride; this is giving rise to a sense of freedom to innovate, use fresh
thinking and interestingly, seems to insulate them from a level of frustration with some
issues such as IT, which in other Government departments has become a much greater
barrier to delivery.
1.17. The reviewers considered that the communications team were being asked to deliver on
too small a budget, so we were pleased to hear that the Board had decided to increase
programme budget for 2015/16. That said, the team seemed resilient about their
financial constraints, and indeed felt that limited resources had given rise to more
innovative and partnership approaches that had worked well.
Implementation
1.18. The team are clearly ‘deliverers’ and have achieved some considerable successes, not
least the recent Civil Service Award and Corporate Communications Award. The digital
team and its leadership stood out as a particular pocket of excellence.
1.19. They have a strong campaign ethos, where high profile, big moment campaigns are
executed to a high standard.
Areas for improvement
Strategy and planning
1.20. The top priority should be to develop a long term communications strategy to underpin
the organisation’s overall strategy. This needs to move beyond a description of key
projects and campaigns and instead provide an evidence based articulation of the
principles and the choices that will inform where communication’s attention and
resources will be invested. The FSA’s strategy is wide ranging and ambitious and
communications is integral; however there are some big decisions to be made about the
topics, audiences and stakeholders that will form the basis of FSA communications in the
years ahead. We encourage the DoC, in partnership with the Board, to grapple with this
strategic challenge as a matter of priority. Without doing so, there is a significant risk of
opportunity missed and a likelihood that communications will fail to deliver its full
potential. From this strategy work will come the ‘compelling strategic narrative’ that is a
pre-requisite for a successful strategy.
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1.21. Also integral to the strategy will be improved audience segmentation (the organisation
needs to go beyond ‘the consumer’), and undertake a longer term approach to planning
so that communications campaigns are delivering outcomes over the lifespan of the
strategy. Improved metrics and evaluation will also be key here. A refreshed approach to
stakeholder management should also be a priority. The reviewers were genuinely
concerned about what appeared to be a breakdown in relations with some stakeholders;
and whilst we were very conscious of the organisations responsibility to drive change, our
view is that this would be better achieved through a more sustained and strategic
approach to stakeholder relations.
People and resources
1.22. Internal communications is an area for concern; whilst the reviewers thought that the
leadership of that team was very able, the structure positioned internal communications
as a more junior partner and the location of the projects team within that function was
potentially a distraction/drain on the internal communications resources. The panel also
considered that there was scope for the organisation to become a more ‘intelligent
customer’ of internal communications; that there should be a strategic ambition for
internal communications to match the ambition held for external communications.
1.23. As already noted, we think that the stakeholder function is in need of a re-appraisal. It is
also of concern that the press office function has been reduced to a skeleton size; while
this may not seem like a problem during ‘business as usual’ periods we would question
the press office’s ability to withstand another horsemeat-scale crisis. The reviewers
recommend some robust contingency and crisis communications plans to address this.
Our final observation is that if the DoC is to carve time out in order to deliver on the big
strategic challenge we have identified, we think the function needs a formal deputy.
There wasn’t one obvious candidate for this; we were impressed with a number of
members of the communications SMT but an effective deputy needs significant gravitas
internally and externally and we suggest that the DoC might want to consider a
recruitment exercise to fill this position.
Implementation
1.24. As noted above and inextricably linked to strategy development, is the need to
concentrate on audience segmentation, planning, metrics and evaluation. We know that
this work is underway, but recommend that this is accelerated.
1.25 The FSA’s communications function is operating in a similar vein to an NGO; in the best
sense this means they have zeal, cause and a commitment to deliver -it is at times
‘punching above its weight.’ However, the absence of long term planning (combined with
limited resources) means they run the risk that other communications priorities become
lost or subordinated to the one ‘big’ issue or news moment. Our view is that the
communications function needs some clear long term objectives that defines ‘areas for
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participation’ and which are underpinned with rigorous plans which will enable them to
deliver on a number of fronts over a sustained period of time.
Recommendations
1.32. This report has four main recommendations:
i. A robust, evidence based communications strategy is now needed, it should
clearly articulate the rationale for FSA communication priorities and be
underpinned with tight objectives, robust audience insight, planning and
evaluation
ii. The Director of Communications should appoint a deputy in order to free up his
time to drive the above strategy
iii. Internal Communications needs levelling up to the status and strategic ambition
of the other communications functions
iv. Stakeholder relations is need of an overhaul; given its increasing importance
(and complexity) and the poor state of some of FSAs stakeholder relationships
we would recommend this as a priority
Actions
1.33. To achieve the outcomes intended by the report’s recommendations, the reviewers have
suggested some specific actions for implementation in six and twelve months
Item Action in six months Action in 12 months
Item examples:
Communications Appoint a deputy to ‘free up’ Long term, evidence
strategy DoC to build long term based communications
strategy strategy in place.
DoC and Board agree the Articulates where and why
topics, audiences and communication’s
stakeholders that will form attention and resources
the basis of FSA long term will be invested,
communications strategy underpinned by plans.
Supported by agreed
‘compelling strategic
narrative’
Internal Review of seniority and Reset relationship with
communications responsibilities of Internal HR, clarify ownership of
Communications leadership engagement and agree
organisational outcomes
that are being pursued.
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Stakeholder Review current resourcing Build strong ‘enabling’
management and priority given to capability; that
stakeholder management strategically advises and
practically supports FSA’s
stakeholder relations.
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