Policy paper

Annex C: public-facing communications protocol

Published 28 September 2022

Applies to England

General

‘Annex C: public-facing communications protocol’ is an annex to the main framework agreement which defines the critical elements of the relationship between the Department of Health and Social Care (DHSC) and NHS Business Services Authority (NHSBSA).

The framework agreement sets out how the department and NHSBSA discharge their accountability responsibilities effectively. The framework agreement makes clear that the Secretary of State is accountable to Parliament for the health system as its ‘steward’, including NHSBSA, and that the department’s Permanent Secretary (as the principal accounting officer) is accountable to Parliament for the issue of any grant-in-aid to NHSBSA.

This annex sets out the basic principles guiding co-operation and collaborative working between the department and NHSBSA across all aspects of communication and marketing activities to deliver impactful and cost-effective communications in the context of our shared accountability to Parliament and the public.

The principles are supported by and reflected in the jointly agreed health and care communications operating model that provides the operational framework for our co-operation.

The Director of Communications in the department and the Head of Communications and Marketing at NHSBSA will ensure this document is shared, understood and adhered to across all communications functions and by all relevant members of staff, including where appropriate central, regional and local teams.

The department and NHSBSA commit to regularly reviewing the effectiveness of the arrangements described in this annex via Director of Communications calls and other regular meetings and discussion forums. NHSBSA will identify opportunities for shared learning and improvement and also identify any further amendments that may be required to this document over time.

This annex is supported by a number of formal and informal networks and meetings that provide further opportunities for agreement on joint working in relation to specific communications functions and activities. In addition to these networks, the department and NHSBSA may propose the development of additional agreements to address specific issues. These agreements will have the same binding function as the annex.

Principles of co-operation

The department and NHSBSA have agreed on the following principles of co-operation, building on the health and care communications operating model agreed by the former Health Hub in May 2017, and which apply to all areas of our communications activity.

We have mutual respect for the different roles and responsibilities of each organisation.

We recognise that each organisation has unique objectives and responsibilities related to its specific role within the health and care system which impacts on its communications activity.

This means that we agree, for instance, that the department and NHSBSA will continue to establish and maintain independent relationships with all those interested in or affected by each organisation’s work, including the media.

We co-operate and co-ordinate our work.

We recognise that each organisation has a unique role and purpose within the health and care system. However, we also agree that co-operation and co-ordination around external and internal communication is necessary in order to maintain public confidence in the health and care system.

On the basis of our jointly agreed operating model, we will regularly identify and agree shared priority areas of co-operation and integrated working that support the health and care system’s shared priorities. We will agree and implement an integrated communications approach for those areas and ensure this approach is fully embedded across organisations.

We operate a ‘no surprises’ policy.

We keep each other informed and updated on any issues that may impact on or affect other organisations or departments, ministerial or wider government priorities, or any issues that may have a reputational impact on the system.

We will do this in a timely manner to allow others to react and/or provide input in advance of content being shared with the public, media or other stakeholders.

In particular, we agree that NHSBSA and the department should give each other sufficient advance notice and sight of decisions or publications in order to allow the department or NHSBSA to consult or seek any clearances (including cross-government clearance) that may be required prior to the publication of a report or announcement that sets policy or has operational, financial or policy implications.

We will ensure that policy and sponsor colleagues are informed about any decisions, announcements or consultations of which we are aware.

We will use established communications routes such as weekly teleconferences, media-planning grid discussions and other forums in an open and transparent manner to keep each other informed, and we commit to supplementing these conversations through other additional information exchanges if and when appropriate.

We seek to enhance the efficiency and effectiveness of our work.

We will strive to share skills, best practice and resources in order to increase the efficiency and effectiveness of our work. We will use the joint forums to identify and agree areas where this is possible and of benefit to all involved.

We will scrutinise major paid-for communications and marketing activities to ensure best value for money is achieved.

We will seek to identify areas where, through co-operation and co-ordination across the health and care system, we can achieve additional efficiencies.

There may be exceptional circumstances, such as legal cases or data protection issues, where adhering to these principles may be challenging. We agree to seek to resolve such issues mindful of our overarching shared responsibility to maintain public confidence in the health and care system at all times.

The operating model will be kept under review and may be amended as circumstances require. However, changes will require the agreement of the majority of Health Hub members and be supported by the Director of Communications of the department, as the group head of profession.

The areas of shared interest and co-operation are grouped around 3 broad headings:

1. Strategy (shared plans): how we jointly agree on areas of co-operation and how that co-operation is put into practice and its implementation monitored.

2. Standards: how we maintain the highest professional standards and capability to build a skilled workforce which works effectively and efficiently, and adopts innovation and industry global best practice.

3. Spend: how we ensure that paid-for communications and marketing activity supports our shared priorities, is of the highest professional standard and achieves best value for money.