Association of Professional Political
Consultants (APPC) (P9)
1. INTRODUCTION
1.1 The Association of Professional Political
Consultants (APPC) welcomes the opportunity to contribute to the
Procedure Committee's inquiry into e-Petitions. The APPC is the
representative and regulatory body for UK political consultants
and public affairs professionals. Membership of the APPC is open
to any political consultancy providing services to the UK institutions
of central, regional and local government and/or other public
bodies. The APPC represents approximately 80% of the industry.
The APPC's Code of Conduct applies the principles of openness
and transparency and that there should be no financial relationship
between political consultancy and Parliamentarians. In the view
of the APPC, it is inappropriate for a person to be both a legislator
and a political consultant.
1.2 The APPC has three main roles:
(i) To ensure openness and transparency of
activities and dealings by member consultancies. The APPC maintains
a register of political consultants, together with a list of the
fee-paying clients that they represent. Members are required to
update their register entry every three months. The register is
published on the APPC's website and is easily accessible. Members
are also required to disclose the identity of their clients and
not misrepresent their interests when making representations to
institutions of government.
(ii) To enforce high standards of ethical
and professional behaviour by requiring all members to adhere
to a Code of Conduct in their dealings with institutions of government.
It is a condition of membership of APPC that the member firm,
its staff and its non-executive consultants should accept and
agree to abide by this Code. Where members already operate their
own internal codes, they are obliged to incorporate the APPC code
and its provisions may not be overridden or materially amended.
Members are also required to submit to the APPC
procedures to ensure compliance with the code, including an annual
statement of compliance with the recommendations on professional
practice that was produced for the APPC by Lord Armstrong of Ilminster
and Nicholas Purnell QC. Members are jointly and severally liable
for the actions of their staff in relation to the Code. Regulated
political consultants are required to endorse the Code and to
adopt and observe the principles and duties set out in it in relation
to their business dealings with clients and with all institutions
of government.
(iii) To promote understanding amongst politicians,
the media and others about political consultants and the public
affairs sector, as well as the contribution made by political
consultants to a properly functioning democracy
1.3 Political consultants are employed by a
wide range of organisations which need to understand and engage
with the policy making process, including charities and campaigning
groups, trade associations, professional bodies, trade unions
and public sector bodies. Consultants are also employed by local
government and central government agencies and departments, as
well as international governments. Analysis of the APPC register
shows that approximately 40% of APPC members' clients were non-commercial
organisations in 2005. All of these organisations pay for the
services of a political consultant to provide public affairs advice,
in the same way as they might hire an accountant or lawyer to
provide accountancy or legal advice.
1.4 It is important to note that many organisations
and bodies—commercial, voluntary sector and local government—directly
employ one or more public affairs professionals in-house to provide
similar services as those provided by political consultancies.
The APPC does not represent, or attempt to regulate, the activities
of in-house public affairs practitioners.
2. SPECIFIC QUESTIONS
RAISED BY
THE PROCEDURE
COMMITTEE
2.1 The APPC believes that the right to petition
for redress of grievance is fundamental to democratic systems.
If Parliament is to remain central to the exercise of this right,
it is essential that it should modernise its arrangements to take
account of today's technologies. So, in our view, refreshing the
current arrangements around petitions including allowing for the
consideration of e-Petitions is a timely and appropriate measure
that would help bring Parliamentary procedures into line with
current online practices. We therefore agree with the creation
of a web-based database of petitions and responses as proposed
in the Procedure Committee's Report on Petitions and endorsed
in the subsequent Government response.
2.2 Parity with written petitions. We believe
that the signing of an electronic petition should be viewed as
the same as the signing of an offline petition. As a result the
APPC believes that Members of Parliament, and Government as a
consequence, should engage with e-petitions as they do with written
petitions. Furthermore the APPC believes that once formally presented
e-petitions should have the same status as written petitions.
Indeed, due to the increasing penetration, familiarity and adoption
of online communication methods by the population we believe that
e-petitions could soon become the standard form of petitioning
Parliament allowing for an easier, simpler and more responsive
petitioning system than is currently in place.
2.3 Parliamentary e-Petitions versus Downing
Street e-Petitions. Our members have noted that the decision to
introduce the Downing Street petition website has captured a real
appetite for online political engagement amongst the general public.
Indeed, as political consultants we have noted a tangible increase
in the number of clients, both from the private and third sectors,
employing this tactic in the promotion of their particular objectives.
By providing a medium for members of the public to support their
causes we believe Government is better informed about public opinion
and can make more informed judgements. Moreover, the impact made
by some high profile petitions online have fundamentally changed
the way in which e-petitions are regarded by the public affairs
industry and we believe it is appropriate that Parliament as well
as the executive has the ability to accept petitions in this manner.
2.4 Operation of an e-petition system. We believe
the Procedure Committee should pay close attention to how e-petitions
would operate in practice. The immediacy of the online medium
offers members of the public an opportunity to present petitions
almost in real-time. Assuming a functionality similar to that
of the Downing Street website members of the public could submit
e-petitions in real-time and using modern forms of communication
(e-mail, mobile and social networks) could rally the support of
a large cohort relatively easily. We believe attention should
be paid to ensure that the ease of this system is not abused but
that it is sufficiently flexible to enable debate and discussion
of high-profile issues that have caught the attention of the public.
2.5 e-Petition ownership. This is one of the
most important and challenging of the issues to be considered.
We note the Government response to the Committee's first report
on petitions that e-petitions should not break the link between
Members of Parliament and petitioning Parliament and that this
right should not be afforded to individuals. We understand the
argument that the principles of a representative democracy should
be maintained in permitting MPs rather than individuals to present
petitions, whether electronic or written, to Parliament. The APPC
notes that this raises interesting questions as to how an e-petition
is to be tabled and who "owns" it. Is the "owner"
of an e-petition the first signatory and drafter of the petition—as
on the Downing Street petition website—or is it a Member
of Parliament? Furthermore, in order to be considered for consideration
by the House and subsequently the Government, would a Member of
Parliament need to "adopt" a petition or should only
petitions tabled in an MP's name be permitted on the system in
the first instance for members of the public to sign? We believe
that in coming to a decision on this issue the Committee should
consider the need to balance flexibility and the ability of the
public to draft, table and construct a petition quickly with the
need to maintain the role of Members of Parliament.
2.6 Format of e-Petitions. The APPC believes
particular attention should be paid to how signatures can be amassed
on an e-petition in order that the e-petition is valid and able
to be accepted by the Speaker for formal presentation on the floor
of the House. The Committee will need to give some thought to
the possibility that the introduction of online petitioning could
lead to a very substantial increase in the volume of petitioning.
The APPC believes that the Committee should consider scenarios
whereby the supply of e-petitions outstrips the availability of
presentation slots in the order of business in the House of Commons.
If so, should consideration be paid to allowing the presentation
of a petition without the formal ceremony in the House—a
form of e-tabling on behalf of a Member of Parliament directly
to a Government Department along the same lines as the current
e-tabling system—or should slots be allocated based on number
of signatories or by ballot?
2.7 Refreshing Petition Language. The APPC supports
measures to renew and refresh the historic Parliamentary language
associated with petitions. Whilst we note it is important to retain
the ability to present petitions in a traditional manner we also
believe that in order to reflect the essential right of a Member
of Parliament to accurately represent the views of petitioners
and have this fully understood by those making the petition it
is appropriate to use clear and easily understood plain English.
The APPC believes, as a consequence, that any web-based e-Petitioning
system should apply plain English rather than historic English
as permitted when presenting petitions on the floor of the House.
Clear guidelines should be available as to what format an e-petition
should be drafted in, what a petition can call for and how it
is to be regarded. In all cases, the APPC believes, effort should
be taken by the Procedures Committee to ensure that these guidelines
encourage rather than discourage the electronic petitioning of
Parliament.
2.8 Response timeline. The APPC agrees with
recommendations that the Government should respond to formally
tabled e-Petitions within two months ensuring that there is a
clear and apparent connection with the will of petitioners to
bring an issue to Parliamentary and Government attention and the
right to receive a formal response from Government. We believe
this "right of reply" by Government is an essential
part of the democratic process and should not be lost with the
introduction of e-petitions, although we note that this may have
resource implications for Government departments, as we believe
refreshing the guidelines around petitions will inevitably encourage
more members of the public to petition Parliament. We believe
that this is a cost worth shouldering in the pursuit of a more
open and transparent democratic system.
2.9 e-Petitions as a catalyst for wider reform.
The APPC believes that refreshing the ability to petition Parliament,
via a Member of Parliament, could represent the catalyst for the
wider objective of improving how Parliament connects with the
public. Indeed, in order to install the online infrastructure
for an e-petition system, Parliament may also wish to look further
into online tools to enhance the accountability and transparency
of Parliament, such as greater use of video and RSS feeds. We
believe that there is a substantial opportunity for the UK Parliament
to lead the world in e-petitions by developing, in conjunction
with an online database e-petitioning system, widgets and applications
that log a signature against a petition from websites other than
on the e-petition system. By developing applications to be hosted
on social networks and websites a greater number of people would
have the ability and opportunity to sign electronic petitions
to Parliament.
November 2007
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