17 December 2025
T.D. Price
[FYI request #32609 email]
Dear T.D
Official Information Request
Our Ref: OIA 2025-0130
I refer to your official information request received on 21 October 2025 for information
regarding the Public Service Commission's (the Commission’s) social media and digital
advertising campaigns concerning strike action scheduled for 23 October 2025, and any
other industrial or employment relations activities in 2025.
As you were advised on 18 November 2025, we extended your request to 17 December 2025
as your request necessitated a search through a large quantity of information and meeting
the original time limit would unreasonably interfere with our operations, and consultations
needed to make a decision on your request were such that a proper response could not
reasonably be made within the original time limit.
Background information
Under the Public Service Commissioner’s (the Commissioner’s) role as Bargaining Lead for
school teachers and principals in the education sector, the Commission has been following
an overarching communications strategy designed to ensure clear, consistent, informed
and timely communications with stakeholders and the public during the extended period
of bargaining.
Upon learning of a coordinated day of union strike action (the Day of Action), the
Commission developed a targeted communications strategy specifically focused on
addressing the day’s events and the potential impact for the public. The social media
messaging relevant to your request was created within the framework of that
communications strategy.
The development of the social media messaging, as part of this strategy, was informed by
advice from the Commission’s Legal, Integrity, Workforce and Communications teams.
Throughout the process, advice from relevant subject matter experts shaped the content
to ensure accuracy and compliance with the Government Advertising guidelines and
Commission’s social media guidance, under extremely short timeframes.
As publicly reported by the Office of the Auditor-General
(Decision to purchase social media
advertisements — Office of the Auditor-General New Zealand), the Commission has
recognised there might be lessons it could learn from the process it fol owed. The Public
Service Commissioner has decided to engage an external party to carry out a review of this
matter, and the Auditor-General has advised that he expects the review to be
comprehensive, robust, and transparent.
Level 10, Te Iho | 1 Lambton Quay | PO Box 329
Wellington 6140 | New Zealand
Phone +64 4 495 6600
Our response to your requests
For ease of reference, we have listed each of your requests (numbered 1 – 18) and provided
our responses directly underneath. Please note that throughout the documents released,
information that is not related to social media post have been marked ‘out of scope’.
PDF titled Pack A: Parts 1, 3 and 18
Part 1
Al documents, briefings, emails, and communications relating to the decision
to undertake social media and digital advertising campaigns regarding the 23
October 2025 strike action and any other industrial or employment relations
activities in 2025, including who authorised them and when.
Part 3
Al documents showing which Public Service Commission executives and
senior managers were aware of or involved in approving these campaigns.
Part 18
Any assessment of whether this activity is consistent with the principle of
public service political neutrality
Documents in the
PDF pack titled Pack A are documents within scope of parts 1, 3 and 18
of your request. I have decided to release the relevant parts of these documents, subject to
information being withheld under one or more of the following sections of the Official
Information Act 1982 (OIA), as applicable:
• section 9(2)(a) – to protect the privacy of natural persons, including deceased people
• section 9(2)(h) – to maintain legal professional privilege
• section 9(2)(g)(i) – to maintain the effective conduct of public affairs through the free
and frank expression of opinions by or between or to Ministers of the Crown or
members of an organisation or officers and employees of any public service agency
or organisation in the course of their duty
• section 9(2)(g)(ii) – to maintain the effective conduct of public affairs through the
protection of such Ministers, members of organisations, officers, and employees
from improper pressure or harassment.
Regarding part 3 of your request ‘
Al documents showing which Public Service Commission
executives and senior managers were aware of or involved in approving these campaigns’,
the development of the social media messaging, as part of the Commission’s broader
communications strategy, was informed by advice from the Commission’s Legal, Integrity,
Workforce and Communications teams. Throughout the process, advice from relevant
subject matter experts shaped the content to ensure accuracy and compliance with the
Government Advertising guidelines and Commission’s social media guidance.
However, I have decided to withhold the names of staff members, other than the Public
Service Commissioner’s, under sections 9(2)(a) and 9(2)(g)(ii) of the OIA. Information that
indicates whether an email was sent internal y (within the Commission) or external y (i.e.,
to the Office of Hon Judith Collins KC or another Public Service agency) is included in the
information released.
PDF Titled Pack B: Parts 9, 10 and 11
Part 9
Al documents outlining the objectives, target audiences, and key messages of
these campaigns across al platforms
Part 10
The planned duration of each campaign and geographic/demographic
targeting parameters for each platform used
Part 11
Al creative briefs, draft content, and approved final content for the
advertisements across al platforms for al industrial or employment relations
campaigns in 2025. Please include any screenshots or proofs that were
released of any campaigns including dates publicly shown.
I have decided to release the relevant parts of the documents released in the
PDF pack
titled Pack B, subject to information being withheld under one or more of the following
sections of the Official Information Act 1982 (OIA), as applicable:
• section 9(2)(a) – to protect the privacy of natural persons, including deceased
people
• section 9(2)(g)(ii) – to maintain the effective conduct of public affairs through the
protection of such Ministers, members of organisations, officers, and employees
from improper pressure or harassment.
• section 6(a) – information would be likely to prejudice the security or defence of
New Zealand or the international relations of the Government of New Zealand
Regarding your request for the target audiences of this campaign, and the
geographic/demographic targeting parameters used, we can confirm the posts were
boosted using Meta’s automated targeting. As stated in our communications strategy our
audiences were people affected by the strikes and the wider public.
PDF Titled Pack C: Part 2
Part 2
Al documents showing which Ministers were informed about these
campaigns, when they were informed, and any responses or direction
provided.
I have decided to release the relevant parts of documents in the
PDF pack titled Pack C,
subject to information being withheld under one or more of the fol owing sections of the
OIA, as applicable:
• section 9(2)(a) – to protect the privacy of natural persons, including deceased people
• section 9(2)(j) – to enable a Minister of the Crown or any public service agency or
organisation holding the information to carry on, without prejudice or disadvantage,
negotiations
• section 9(2)(g)(ii) – to maintain the effective conduct of public affairs through the
protection of such Ministers, members of organisations, officers, and employees
from improper pressure or harassment.
• section 9(2)(g)(i) – to maintain the effective conduct of public affairs through the free
and frank expression of opinions by or between or to Ministers of the Crown or
members of an organisation or officers and employees of any public service agency
or organisation in the course of their duty.
Information publicly available
The Minister for the Public Service, Hon Judith Collins KC has answered a number of Written
Parliamentary Questions (WPQs) on this topic. The following information is also covered by
your request and is publicly available on the Beehive website at the link provided for in the
table below.
Item
Date
Document Description Website Address
WPQ
24 November 2025 WPQ 53190 (2025)
53190 (2025). Francisco
53190
Hernandez to the Minister for
the Public Service
We have also provided a copy of this WPQ below, for your ease of reference:
53190 (2025). Francisco Hernandez to the Minister for the Public Service: Did the Public
Service Commission's communications strategy regarding the industrial action held on 23
October 2025 that was discussed with the Prime Minister contain references to paid social
media advertisements?
Hon Judith Collins: The Public Service Commission’s communications strategy was
provided to my office on three occasions: On 10 October 2025, my office received the
Commission’s communication strategy, which did not include social media plans. This is
the version that was discussed with the Prime Minister and myself. On 14 October 2025, my
office received the Commission’s updated communications strategy which outlined that it
would use targeted social media to reach audiences most affected by the strikes as well
as the wider public. On 17 October 2025, the Commission sent my office an updated
communications strategy which outlined that it would use targeted (paid) social media to
reach audiences affected by the strikes as wel as the wider public. On the evening of 13
November 2025, my Office discovered that it had in fact been informed on 17 October 2025
that the targeted social media campaign was paid. The information published on social
media was publicly available factual information. The messages were distributed via a
channel previously used by the Commission. The Commission has paid for targeted social
media before, most recently in 2022.
Pack D: Parts 5, 6, 7 and 14
Part 5
The total budget al ocated to social media and digital advertising campaigns
regarding the 23 October 2025 strike action and any other industrial or
employment relations activities in 2025, across al platforms
Part 6
The actual expenditure to date, broken down by:
- Each specific campaign or industrial/employment relations issue.
- Platform (including but not limited to Facebook, Instagram, other Meta
platforms, X/Twitter, LinkedIn, TikTok, YouTube, Google Display Network,
Google Search ads, and any other social or internet advertising platforms)
Part 7
Al invoices, quotes, and payment records related to these campaigns across
all platforms
Part 14
A complete list of al social media and internet platforms where paid
advertising was placed regarding the 23 October 2025 strike action or any
other industrial or employment relations activities in 2025.
For parts 6 and 7 of your request, I have decided to release the relevant parts of the
documents in the
PDF pack titled Pack D, subject to information being withheld under one
or more of the following sections of the OIA, as applicable:
• section 9(2)(a) – to protect the privacy of natural persons, including deceased
people
• section 9(2)(g)(ii) – to maintain the effective conduct of public affairs through the
protection of such Ministers, members of organisations, officers, and employees
from improper pressure or harassment.
In response to part 5 of your request, the Commission does not have a specific advertising
budget. Costs were met out of the Commission’s overall communication budget which is
funded through the Vote Public Service ‘Leadership of the Public Management System’
appropriation. Consideration was given to recovering these costs from agencies involved,
but given the final costs of $426, this was absorbed by the Commission. Note: the approval
amount for spend included in Pack D was overestimated based on other agencies’ costs for
similar social media content.
In response to part 14 of your request, the only social media platform used for the boosted
social media posts was Facebook.
Pack E: Part 12 of your request
Part 12
Any analytics, reach statistics, or performance reports for these
advertisements across al platforms
In response to part 12 of your request, I have decided to release in ful documents in the
PDF pack titled Pack E.
Part F: Parts 15 and 17
Part 15
A complete list of al industrial or employment relations matters for which PSC
undertook paid social media or digital advertising in 2025, including dates and
brief descriptions of each campaign
Part 17
Details of any previous occasions (prior to 2025) where PSC has used paid
social media or digital advertising regarding industrial action, strikes, or
employment negotiations
In response to parts 15 and 17 of your request, the social media posts published from
8:00am 18 October 2025 to 9:00pm 20 October 2025 and 6:00am 21 October 2025 to 9:00pm
22 October 2025 (i.e., the scope of this request) are the only paid social media posts the
Commission has undertaken on the topic of industrial or employment relations.
Pack G: Parts 4, 8 and 13
Part 4
Any legal advice sought or received regarding the appropriateness of using
public funds to advertise against lawful strike action or regarding other
industrial or employment relations matter
I am refusing part four of your request for legal advice under s(9)(2)(h) of the OIA in order to
maintain legal professional privilege. I have considered the public interest in this
information and have determined it is outweighed by the need to maintain the integrity of
legal privilege and ensure the Commission can receive candid legal advice to support lawful
and effective decision-making.
Part 8
Details of any contracted agencies or consultants involved in these
campaigns, including their fees.
Part 13
Al communications with Meta/Facebook, Google, X/Twitter, LinkedIn, TikTok,
YouTube, and any other platform providers regarding the placement and
management of these advertisements
I am refusing parts 8 and 13 of your request for the details of any contracted agencies or
consultants and communications with social media providers under section 18(e) on the
grounds that the information does not exist.
Pack H: Part 16
Part 16
Any policies or guidelines governing PSC's use of paid social media and digital
advertising for industrial relations matters.
The following information is covered by part 16 of your request and is publicly available on
Commission’s website at the link provided for in the table below.
Item Document Description Website Address
1
Guidelines: Government
Guidelines: Government advertising - Te Kawa
advertising
Mataaho Public Service Commission
Due to the volume of information requested, the documents are currently being prepared
for release and will be publicly available on the Commission’s website on or before 9
January 2026. We will notify you as soon as they are available.
Administrative in nature
We have not included documents that we have deemed administrative in nature such as:
• communications setting up meetings
• communications pertaining to the logistics of paying for the advertisements (e.g.,
via credit card)
• pages with only signature blocks
• emails that have been duplicated across the response, where possible.
In making my decision, I have considered the public interest considerations as outlined in
section 9(1) of the OIA.
If you wish to discuss this decision with us, please feel free to contact
[email address]. You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at
www.ombudsman.parliament.nz or freephone 0800 802 602.
Please note that we intend to publish this letter (with your personal details removed) and
enclosed documents on the Te Kawa Mataaho Public Service Commission’s website.
Yours sincerely
Nicky Dirks
Manager – Ministerial and Executive Services
Te Kawa Mataaho Public Service Commission
Document Outline
