Audit of Communication Practices

Objectives

The overall objectives of the engagement were to:

• Identify, document, assess and report on the design and operating effectiveness of the Canadian Grain Commission's Internal and External Communications Practices.
• Provide the Chief Commissioner assurance on whether the Canadian Grain Commission's internal and external communications practices effectively support organizational initiatives and are compliant with the Government of Canada Policy on Communications and Federal Identity, the Directive on the Management of Communications, and/or best practices.

Scope

The scope of the audit included communications management processes and practices and related internal and external communications activities undertaken by the Communications group between April 1, 2021 to 31 December 2022.

The audit focused on assessing:

• Governance, strategy and planning considerations;
• Communication approaches employed to reach and interact with internal and external target audiences;
• Communications function resourcing and operational considerations.

Communications activities and approaches undertaken during the audit period were impacted by the recent Covid-19 pandemic. For example, the Canadian Grain Commission attendance at industry trade shows to support the engagement of external stakeholders was paused during the pandemic as many events were cancelled. As a result, the audit scope was expanded in limited cases to include examination of pre-pandemic communication activities where considered relevant.

Additional information on the audit lines of enquiry and audit criteria can be found in annex B.

Approach

The audit approach included the conduct of a range of focused audit procedures, including:

• Review and analysis of CGC corporate strategic and operational planning documents;
• Review and analysis of communications function planning and organization/resourcing information;
• Review and analysis of relevant policy guidance and compliance documents;
• Structured interviews with a range of stakeholders involved in internal and external communications, including Commissioners, Executive Management Committee members, communications function leadership, staff representatives, and communications client representatives;
• Review and In-depth case analysis on a sample of specific initiatives focused on the development and delivery of communications with external and internal audiences;
• Assessment of historic and current communications performance measurement data and results.

Statement of Assurance

In our professional opinion, sufficient and appropriate audit procedures have been implemented and evidence has been gathered to support the accuracy of the opinion contained in this report. This opinion is based on a comparison of the conditions as they were at that time with the predetermined verification criteria agreed with management. It focuses only on the processes reviewed. The audit evidence was obtained in accordance with the internal auditing standards of the Institute of Internal Auditors and the Directive on Internal Audit, as required by the Treasury Board Secretariat's Policy on Internal Audit. These elements are sufficient to provide senior management with the rationale for the audit opinion.

Governance and Strategy

The auditor conducted an examination to deterine whether the Canadian Grain Commission has established effective governance to provide oversight and strategic direction and enable effective communication with internal and external targeted audiences. This includes engagement and consultation with key stakeholders to ensure that communication services and activities support organizational and stakeholder needs and establish supporting communication planning and monitoring processes.

Observations: Stakeholder Engagement

We found that CGC has established approaches to engage internal and external stakeholders and identify their communication needs and requirements. These include activities led by the Executive Director of Innovation and Strategy, and the Manager of Corporate Information Services, such as:

• Regular engagement with Commissioners to discuss external communication considerations and needs;
• Regular engagement with senior managers to discuss external and internal communications considerations and requirements;
• Annual engagement of industry stakeholders (e.g. industry association representatives) to present information on emerging issues and key CGC initatives and solicit stakeholder feedback.

These methods are the primary means through which specific communication initiatives (e.g. development of a particular communications product) are identified.

Interviews with CGC commissioners and senior management representatives confirmed their satisfaction with the current level of interaction with the communications function and the group's responsiveness to their needs.

Observations: Communications Planning and Monitoring

We found that Canadian Grain Commission has established governance to provide oversight and direction to the communications group, primarily through a management structure consisting of the communications group manager reporting to the Executive Director, Innovation and Strategy, who reports to the Chief Operating Officer.

We found however that the effectiveness of this governance is impeded by the current state of communications planning and monitoring processes.

Canadian Grain Commission does not maintain an overarching strategic communications plan that describes, for example, communication group objectives, priorities, key tactics/actions and resources required. Instead, communication activities tend to be planned and monitored at a more granular "initiative level" (e.g. a communications plan developed for a specific program such as the Harvest Sample Program).

Auditors were provided with an outdated strategic communications plan – Canadian Grain Commission Global Communications Plan – last developed in 2010. This plan provided an overview/analysis of the key communication audiences (external and internal); key communication challenges and opportunities; communication objectives; strategies (5-year view); resourcing and performance measurement considerations and other relevant information.

Interviews with communications management representatives confirmed that this type of overarching plan is no longer maintained as the relevance and benefit of this approach was questioned and seen as "planning for planning purposes". Rather than developing a strategic communications plan, the communications group undertakes a process to identify key communications implications and requirements stemming from corporate objectives. As an illustration, for 2023/24 and beyond, CGC has defined various corporate priorities or areas of focus (See Figure 1). Supporting these areas of focus are the definition of various initiatives, including the definition of lead responsibility and related deliverables to be actioned to address the area of focus.

While this corporate plan provides a summary of how communication priorities (e.g. Initiative 1 described in Figure 1) align to corporate priorities (Area of Focus 3 described in Figure 1), the communication deliverables listed within the document have not been articulated at a more detailed level, nor does this summary include definition of all communications group priorities. A more detailed definition would serve to summarize the specific activities, timing, resourcing and performance measurement considerations required to achieve each priority. In the absence of this level of definition, it is not clear that the organization has defined the key communication challenges, opportunities or resultant priorities to be addressed over time. It is also not clear that the organization is able to monitor or gain a full understanding of the extent to which the communications group is clearly and effectively addressing these priorities.

In lieu of broader strategic communications planning, we found that communications planning focuses on the more granular development of plans for specific communications initiatives. Examples of this type of planning includes the development of: communication channel specific plans (e.g. annual trade show plan); program specific communication plans (e.g. Harvest Sample Program plan); and communication plans related to specific change initiatives (e.g. communications plan related to a regulatory change such as enhancements to grain grading dispute resolution). While the initiative plans that we analyzed generally established the underlying communication activities and timing, they varied in their definition of key planning considerations such as:

• Clear definition of the communication initiative objectives – to address the question of "why" the initiative is being undertaken;
• Definition and analysis of the targeted audience/s of the communications initiative – to address the question of "who" the communication initiative is focused upon;
• Definition of the key messages to be conveyed to the targeted audiences – to address the question of "what" is being communicated;
• Definition of performance measurement and monitoring approach – to address the question of "how will we know" that the communications initiative has achieved its objectives

Based on these observations, the Canadian Grain Commission has the opportunity to improve the consistency and comprehensiveness of their communications planning processes. This includes:

• definition and documentation of communication priorities in relation to corporate priorities and related considerations such as key client organization/program priorities, key communication audiences, and key communication channels;
• improving the consistency and focus of plans developed in relation to specific communications initiatives;
• Monitoring of progress against defined priorities and plans.

Improved focus in these areas will help ensure that communication resources are invested in matters of highest priority to CGC.

Impact

A strategic plan provides a mechanism and a focus to:

• clearly rationalize, articulate and communicate priorities and
• strengthen governance by establishing accountability for addressing priorities; and providing guidance to translate priorities into operational tactics and implementation plans.

In the absence of this planning focus, Canadian Grain Commission communications management may not have the information they need to ensure the organization's limited communication resources are being invested in areas of highest priority.

Communication Approaches

The auditor conducted an examination to determine whether the Canadian Grain Commission has established communication approaches to support effective communications with its targeted internal and external audiences. This includes having processes in place to identify the communications preferences of target audiences, and whether communications are reaching these intended internal and external audiences.

Observations: Targeted Communication Audiences

We found that Canadian Grain Commission has generally identified the various external and internal audience groups that are targeted for various communications purposes. For example, the 2010 Canadian Grain Commission Global Communications Plan defines and includes analysis of the composition, preferences, and challenges of primary (e.g. western grain producers, farm groups), secondary (e.g. eastern grain producers, research and academic community) and other external audiences of importance to the organization. Communications group management confirmed that while this analysis has not been formally updated since 2010, the categorization and definition of the targeted audience groups remains accurate today.

In lieu of a more formal analysis and generation of insight into targeted communication audiences, CGC employs an ad hoc approach leveraging data points and insight as they become available. For example, the 2010 analysis included third-party research into the preferred communication methods of producers. Also in 2017 the Canadian Grain Commission engaged a third party to conduct a survey on producer and industry perceptions of its services. As these analyses have not been formally updated since 2017, CGC relies on periodic and informal analysis of various data from sources such as Commissioner input, trade show attendee feedback, and other means (e.g. industry research) to determine the continuing relevance and effectiveness of communication approaches in light of changing demographics and communication preferences.

Examples of where this insight has been applied to develop targeted and responsive communication approaches include:

• the use of geo-fenced data (e.g. agricultural area postal codes) to target producers with social media or advertising (e.g. Weather Network) based communications messaging,
• the ramp up, during the Covid pandemic, of advertising in support of the Harvest Sampling Program in lieu of the cancellation of trade shows as a means of reaching producers.
• the discontinuation of Yammer as an employee communication channel in response to feedback received on the effectiveness of this communication approach.

These examples provide indication of communications management focus on analysis of available information, and targeting and tailoring of communications approaches. However, it is unclear whether communications management have identified and articulated the broader ongoing challenges in reaching targeted audiences (e.g. how to ensure communications are ultimately received directly by producers) or the approaches to be undertaken to address these challenges.

No specific recommendation has been raised related to this observation as it represents a consideration of Recommendation 1.

Observations: Communication Reach and Impact

We found that the organization has limited insight into the extent to which communication approaches, practices, products and messaging are reaching their intended/targeted audiences. This finding is raised recognizing that the Canadian Grain Commission, as a small organization within the federal government, has resource constraints impacting its communications performance measurement approach. Also recognized, however, is the critical importance of performance measurement in supporting management decisions such as prioritization and resourcing investments in communication initiatives.

Communications group management has developed a performance measurement framework that defines key areas of communications activity, expected results and supporting performance measures. While this framework conceptually defines expected results and related measures, it has not been fully implemented, nor are performance measures consistently or regularly monitored by communications management or reported upon to CGC senior management. For example, the framework includes measures such as external "survey results demonstrate a level of public awareness and understanding of issues important to the CGC" however CGC has not implemented a surveying/measurement process, nor a monitoring and reporting approach.

Our analysis of a sample of specific communication initiatives confirmed that some elements of performance measurement have been implemented for these initiatives. For example, for trade shows attended by CGC, a report is produced after each trade show summarizing considerations such as:

• Canadian Grain Commission booth attendance and overall tradeshow attendance;
• Engagement considerations such as the number of Harvest Sample Program sign-ups secured, or volume of communication publications distributed;
• Analysis of common questions raised by booth attendees, as an indication of attendee areas of interest and as a source of information to be followed up by relevant program representatives.

Similarly, the communications group has implemented various "activity" performance measures, including measurement of website and social media "click-through" volumes or measurement of Harvest Sample Program sign-up volumes based on various communication channels (e.g. web, phone, trade show).

While the information generated through these efforts provides insight into the level of activity (e.g. how many people attended a trade show booth) related to particular communication initiative, communications management has had limited focus on measuring the results and impact scommunication activities have in enabling, for example, a particular program to meet its overall objectives.

Impact

Performance measurement is key to generating insight into communications function inputs (e.g. resources and tools), activities and outputs (e.g. communications initiatives) and results and impacts (e.g. did we reach intended audience with our message or did we influence intended audience behaviour?). Gaps in this insight impede management's ability to make informed strategic and operational decisions such as "where should we invest our resources to achieve the greatest benefit/impact?".

Communication Operations

The auditor conducted an examination to determine whether Canadian Grain Commission communications resources are effectively organized for optimal service delivery that meets client needs. This includes an expectation that CGC regularly assesses and addresses its communications function resource mix and capacity, skills, and competencies, and has established processes and practices to ensure communication client service needs are being addressed.

Observations: Communications Resourcing

The audit team found communications group management have established a clearly defined organizational structure and delineated roles within the communication group . Staff are organized by specialty area, such as communications content (e.g. writing, editing, translation, community relations) and multimedia (e.g. video, graphic and web design). Work descriptions for the manager and staff roles are also documented.

We found, however, that in relation to effective organization of resources, the communications group does not maintain a summary of planned or "in process" prioritized communications initiatives or work assignments to support day-to-day resourcing decisions. Instead, work assignments are managed on an ad hoc basis which may impede management from ensuring that communication resources are continually focused on initiatives of highest priority.

Further, we found that there has been minimal change in the communications function structure, focus and resourcing levels since 2010 (as documented in the Canadian Grain Commission Global Communications Plan), despite an ongoing shift towards digital approaches as recognized in the 2016 Policy on Communications and Federal Identity:

Canadians increasingly use technology to communicate in their daily lives, and expect to interact with the government in the same way. Using new communications approaches that stem from the rise of digital technologies, balanced with using traditional methods, enables the Government of Canada to reach and engage with Canadians effectively and efficiently in the official language of their choice, regardless of where they reside.

While the organization has adopted some innovation through digital approaches, in some areas, to support communication efforts such as leveraging social media and its internal and external facing websites, this has not been the case in other areas.

In addition, communication clients interviewed encouraged the establishment of a "single point of contact" within communications service delivery to facilitate/minimize their interactions with the various communications group speciality areas (e.g. writing, editing, translation, multimedia) involved in a particular communications intiative.

In order to drive innovation in, and optimization of, communications service delivery, communications group management and other stakeholders interviewed acknowledge a need to undertake a more rigourous analysis of key considerations, including:

• service delivery processes;
• communications group organization and resource mix; and
• required competencies and tools.

This proposed analyses and recommendations , once implemented, would assist the communications group in ensuring they are well-positioned to meet current and future communication needs in an increasingly digital environment.

Impact

Periodic critical assessment of communication service delivery is crucial to maintaining a continual focus on modernization and innovation. Periodic assessment ensures that services continue to be responsive to emerging organizational needs and environment, both internal and external. Periodic assessment also ensures, for example, the required staff competencies and supporting tools are developed and implemented.

In the absence of periodic assessment, communications approaches and methods risk becoming obsolete and unresponsive to stakeholder needs.

Observations: Client Service Expectations

Aligned with auditor findings on stakeholder engagement, we found that the Canadian Grain Commission has established various informal approaches to solicit communication client service feedback and ensure expectations are being met. While not formally measured through means such as client satisfaction surveys, this feedback is generated through, for example, regular communications and communications management engagement of Canadian Grain Commission commissioners, senior management and industry stakeholders.

Interviews with Canadian Grain Commission commissioners and senior management representatives, in their capacity as clients of the communications function, confirmed their satisfaction with the current level of interaction with the communications function and the function's responsiveness to their needs.

Line of Enquiry 1: Governance & Strategy

Effective governance is established to provide oversight and strategic direction and to enable effective communication with internal and external targeted audiences.

• Effective planning and monitoring processes are established to guide the Canadian Grain Commission's internal and external communication activities, to ensure alignment with Government of Canada policies and support of the organization’s objectives and priorities.
• There is regular engagement and consultation with key Canadian Grain Commission stakeholders to ensure that communication services and activities support Commission needs and priorities.

Line of Enquiry 2: Communication Approaches

The Canadian Grain Commission uses a variety of innovative communication approaches to maximize its reach and support effective communications with its targeted internal and external audiences.

• The communications group has established processes to generate insight into its internal and external targeted audiences and their communication preferences.
• The communications group has established processes and practices to ensure that internal and external communications are reaching intended audiences.

Line of Enquiry 3: Communication Operations

Communications resources are effectively organized to deliver communications services that meet client service expectations:

• Effective resource planning processes have been established including assessment of required resource mix and capacity, skills, and competencies to deliver internal and external communication services.
• The communications function has established processes and practices to ensure the Canadian Grain Commission’s communication client service expectations are being addressed.