What is the difference between grassroots communications, mass communications and targeted communications?
Different types of lobbying campaigns
There are different methods by which persons may conduct lobbying campaigns. In some cases there may be a “grassroots” communication where an organisation instructs its members or supporters to contact DPOs on a particular matter. In other cases there may be a mass communication where a person may direct communications at a large number of DPOs. Finally, a lobbying activity may involve a targeted communication directed at one or two particular DPOs. A lobbying campaign can include one of more of these types of communication. The position in relation to “grassroots communications”, “mass communications” and “targeted communications” is set out below.
An organisation (typically a “representative body” or an “advocacy body”) may issue an instruction or directive to its members, volunteers or supporters to make a "relevant communication” (i.e. to lobby) their public representatives or other Designated Public Officials (DPOs) on a particular matter or matters. This is called a “grassroots communication”, because it is made at the grassroots level. However, it is the body directing the communication that has the responsibility to register and submit returns for the lobbying activity, even if the communication was actually made by their members, volunteers or supporters. The individual members, volunteers and supporters would not have to register or submit returns where they are simply following the grassroots directive sent out by the umbrella body.
Grassroots communications may take several forms. A body may direct its members/supporters to write to a local TD, to speak to their elected councilor, to sign a petition or to send a template letter to a government department. The members may – or may not – follow this directive.
The Standards Commission recognises that it would not be practical for the body to keep a record or include details in a return of each "relevant communication" subsequently carried out by its members / supporters on foot of the instruction / directive given by the body.Regardless of the level of engagement, or the outcome of the campaign, this would be considered lobbying and must be registered by the body sending out the directive.
While the Act does not specifically refer to or define a "grassroots communication", a directive / instruction to members to make a "relevant communication" with a DPO is captured by the meaning of carrying on lobbying activities in section 5(1)(b) of the Act. The Act provides that it is the responsibility of the person who makes, manages or directs the lobbying activity to register and submit returns. In such circumstances it is the body which is managing or directing the lobbying activities being carried out by its individual members or supporters. The body must, therefore, include the instruction / directive given to its members / supporters in a return of its lobbying activity(ies), and the register is designed to allow this.
The instruction / directive is recorded as a "grassroots communication" and brief details of the instruction / directive given to the members must be included in the return. Details of the individual DPOs contacted will not be included in the return, nor will details of the members/supporters who actually did the lobbying.
The individual members are not required to register or submit a return unless they a) fall within the scope of the Act themselves, and b) have been involved in lobbying activities which are additional or separate to the instruction / directive given by the body.
Here is an example of a return which includes a “grassroots communication”.
A mass communication is one which is directed at a large number of DPOs at once. For example, in some cases a person (organisation or individual) might decide to communicate with a particular category of DPOs (e.g. all TDs, all Senators etc.). In such cases, provided all DPOs in the category have been communicated with, it is not necessary to name each and every individual DPO within that category. The online register allows the user to include details of what the communication was about and the category of persons targeted. Details of the individual DPOs contacted will not necessarily be included in the return.
The relevant dropdown menu on lobbying.ie does not list each specific Local Authority. Where an individual or organisation has communicated with all members of a particular Local Authority they can select “all Local Authority members” and identify the particular local authority(ies) in the additional text field.
Here is an example of a return which includes a “mass communication”.
In most cases, a person who lobbies will make a targeted communication.
Targeted communications are lobbying activities directed at one or more individual DPOs (e.g. a particular Minister(s) or a particular public official(s)). In such circumstances the DPO communicated with must be specifically identified and will appear on the person’s return of lobbying activities. For example, an organisation may meet with a Minister, write to a TD, or have phone calls on an issue with three individual councillors. Each of these instances would be considered a targeted communication, and the individual DPO or DPOs would have to be identified in the organisation’s lobbying return.