2.1
The committee was asked to consider the impacts of outsourcing and privatisation on the administration of government services. A number of key concerns were raised in evidence. These related to how outsourcing and privatisation of government services impacts upon:
constitutional responsibilities of the government in relation to service provision;
ministerial accountability;
stability, quality and oversight of outsourced services;
the extent to which outsourcing serves the public interest;
economic impacts of outsourcing; and
issues of transparency and access to information in relation to services that are outsourced.
2.2
This chapter also looks at the issue of automation in relation to government services, including evidence around Centrelink’s ‘Online Compliance Intervention’ – the so-called ‘robodebt’ scheme.
Constitutional/democratic responsibilities
2.3
The Australian government has constitutionally-enshrined rights and responsibilities in respect to the provision of many social services and benefits. These are outlined in section 51 of the Constitution and include:
invalid and old-age pensions;
pharmaceutical, sickness and hospital benefits;
medical and dental services; and
benefits to students and family allowances.
2.4
The Centre for Comparative Constitutional Studies highlighted these responsibilities, submitting that the Commonwealth government cannot delegate or abrogate these responsibilities through outsourcing human services. Centre Co-Director, Dr Kristen Rundle, warned that any outsourcing process must consider including ‘appropriate mechanisms of ministerial accountability’ because ‘ministerial accountability to parliament is the backbone of our constitutional system’.
2.5
Dr Rundle explained that introducing private providers into the system of service provision can complicate the chain of responsibility of ministers to the parliament, because ‘commercial-in-confidence and other elements of contracting…can operate to shield the private actors from the full extent of ministerial accountability to parliament’.
2.6
The Centre for Comparative Constitutional Studies’ major concern was in protecting what it saw as a constitutionally-enshrined right to equality for all citizens in relation to the provision of the services outlined in Section 51. Dr Rundle said:
We're concerned to ensure that citizens have the legal standing with respect to government in relation to government services delivery that is equal to them—that there are no barriers to accountability, including ministerial accountability, but other forms of accountability as well.…The Constitution sets up a system for the government of people framed by the authority of the Constitution and the laws of the parliament. We have an expectation that the administration of those laws and programs, with respect to them, will be intelligible, fair and respectful to those who they affect.
2.7
The Centre for Comparative Constitutional Studies argued the robodebt scheme enlivens a number of significant constitutional issues. Specifically, the Centre articulated its view that, ‘[i]t is essential that the relationship between the Commonwealth and those subject to its administrative power be designed and sustained in a manner that is intelligible and respectful’.
2.8
Witnesses argued that poor or inequitable delivery of essential government services and benefits undermines faith in democracy. Dr Travers McLeod from the Centre for Policy Development added:
…poor service delivery outcomes undermine trust in government and diminish our democracy. It would be remiss not to mention yesterday's interim report by the aged care royal commission, appropriately titled Neglect, which makes that clear.
2.9
Anglicare Australia submitted:
Our central contention is that Australian Government services to citizens should be person-centred, transparent, timely and effective for every member of the community who needs to access them. They should be treated and built as fundamental state infrastructure for the creation of a better society.
2.10
Dr McLeod also expressed the view that Australians prefer to see essential services delivered by government:
Our research over two years suggest that three-quarters of Australians think it's important for government to maintain the capability and skills to deliver human services directly. Fewer than one in 10 people think this is not important.
2.11
This view was echoed by the Community and Public Sector Union (CPSU), which referred to research that suggests 82 per cent of Australians ‘want government to retain the skills and capability to deliver services directly’.
2.12
The CPSU also proposed that failures in projects to privatise or outsource public services are ‘more than an issue of public administration’ and go ‘to the heart of our democracy’.
Stability and security of outsourced services
2.13
Evidence presented to the committee by a number of witnesses focussed on the stability and security of outsourced services compared with services that are delivered by government entities.
2.14
Public Services International (PSI) has conducted a significant amount of research into Australian and international experiences of outsourcing. Its representative, Mr Michael Whaites, drew the committee’s attention to examples from the United Kingdom, including ‘the collapse of Carillion’, a large company that held many outsourced government contracts in the UK. Mr Whaites said:
That was a 1.5-billion-pound company, and when it collapsed it caused massive economic disruption in the UK, and disruption to public services and infrastructure expansion.
2.15
Mr Whaites argued that ‘[p]rivatisation is a failed model’, saying that, in Australia, seven hospital privatisations, the privatisation of TAFE and the privatisation of aged-care have all failed and negatively impacted on communities.
2.16
Submitters proposed that outsourcing human service functions may have flow-on effects for other social service providers. For instance, Homelessness NSW reported that its members, who provide services to assist the homeless, have experienced increasing difficulties ‘liaising with government agencies, particularly DHS, to ensure timely and correct advice for their clients.’
2.17
Dr Paul Barnes focussed on issues related to outsourcing services for the Australian Government Security Vetting Agency (AGSVA). Dr Barnes cautioned that government remains accountable for ‘errors in service provision’ made by third party contractors. He suggested the government focus on crisis and continuity planning, and strictly vetting providers in terms of their document and data management and security.
2.18
The Department of Defence responded to concerns about the risks associated with outsourcing AGSVA functions, saying:
All ESVS panel members must be members of the Defence Industry Security Program (DISP). DISP members are required to apply Defence Security policies, including obtaining certification of physical premises and information systems, and personnel clearances for staff handling classified or sensitive information. All DISP members undergo Foreign Ownership Control and Influence (FOCI) checks and are required to provide reporting on security incidents and any FOCI changes.
DISP security requirements are reinforced by the recently established Defence Industry Security Office (DISO), which has responsibly for assuring DISP members compliance. DISO conducts reviews and audits of DISP members (including ESVS panel members) to ensure appropriate security policies, systems and compliance regimes are in place.
Service quality
2.19
Witnesses suggested human services delivered by government entities often provide better service quality than those delivered by private entities. PSI referred to research that found users rate services delivered by government as being ‘more accessible, more affordable, of higher quality and easily more accountable than those delivered by private companies and even by charities’.
2.20
Per Capita submitted that the privatisation of 2,750 Department of Human Services call centre jobs ‘has led to more mistakes with services being disrupted and further delays to the community’.
2.21
The Department of Human Services submitted all of its staff, including non-APS employees, ‘receive extensive training’, learning and development, and ‘are held to the same high standards of performance, accountability and customer service’ as permanent APS staff.
2.22
Vulnerable and disadvantaged citizens, in particular, may be disadvantaged when human services are outsourced, witnesses claimed. PSI pointed to the example of job network outsourcing, saying:
…the experience with employment services was a crucial case and that this entirely outsourced system had blurred responsibility for service outcomes and led to the emergence of pernicious 'grand alibis' where no one organisation was held accountable for service problems or failures. These findings were reinforced in December last year by the McPhee review, which was released by the then Minister O’Dwyer. Here is a $6.5 billion system with poor outcomes, waiting times of more than five years for the most vulnerable, case loads of one to 148 and employer penetration of just four per cent. A primary focus on compliance has meant disadvantaged jobseekers—those with complex needs—stand little chance of success in the procurement based system.
2.23
Dr McLeod reported that the Centre for Policy Development has been conducting research into the ways in which ‘cycles of disadvantage have been accelerated by service failure and fragmentation’. He pointed to examples where disadvantaged citizens were subject to ‘repeated assessments’ and had to ‘tell their story over and over again’, and where people were treated differently by private service providers depending on how much funding they were able to access. The research ultimately found:
…that a predisposition by recent governments to outsource human services risks poor outcomes for the most disadvantaged Australians and erodes public-sector capability to design and, where necessary, deliver effective services for our most vulnerable people.
2.24
The Centre for Policy Development also highlighted issues with the privatisation of the aged care system. Dr McLeod argued that treating older people as consumers was problematic because many ‘are not in a position to meaningfully negotiate prices, services or care standards with aged-care providers’. He added that older people have ‘little choice’ within the aged care market, meaning aged care is not a ‘consumer driven market’, though it may appear to be one.
National Disability Insurance Scheme
2.25
Some submitters expressed positive views about certain aspects of outsourcing in the delivery of the National Disability Insurance Scheme (NDIS), including Uniting Communities, which submitted:
Outsourcing service delivery has a positive impact on service provision including efficient use of a localised work force, leveraging existing community relationships and infrastructures and increased flexibility and responsiveness with of not for profit organisations.
2.26
However, other submitters were concerned about outsourcing of NDIS functions, including Queensland Advocacy Incorporated, which submitted that the decision to outsource the operation and staffing of the NDIS call-centre to private multinational company, Serco, was ill-advised and likely to negatively impact people with disabilities and their carers.
2.27
Queensland Advocacy presented the results of a survey it conducted of users of the NDIS call centre, which found:
…a significant proportion if not a majority of callers to the Serco-run service are not satisfied with the understanding, knowledge or interpersonal skills of call takers, or the gate-keeping function of the service.
2.28
Dr Darren O’Donovan from La Trobe Law School criticised the ‘heavy reliance’ within the NDIS on ‘insourced expert reports and legal representation in tribunal matters’. Dr O’Donovan suggested the NDIA should be funded to increase its own legal team instead.
2.29
People With Disabilities Western Australia also reported significant stakeholder issues with the call centre and other aspects of outsourced service delivery, including that call centre staff lacked knowledge and training.
2.30
This view was echoed by People With Disabilities Australia, which recently conducted a survey of around 900 people with disability which found ‘most’ (67 per cent) reported ‘difficulty accessing government services and agencies’, and many ‘had experienced discrimination and disrespect from government agencies including Centrelink and the NDIA’.
2.31
Consumers are not always individual citizens. The Australian Small Business and Family Enterprise Ombudsman submitted evidence on negative impacts caused by the NDIA outsourcing assessments of incorporated NDIS service providers to private auditors. The Ombudsman reported:
Companies are required to go through surveillance audits in the second and third year of their participation. The outsourced auditors apply the same processes for small providers delivering one service to 10 clients and large providers delivering 10 services to 100 clients.
Oversight and quality control
2.32
Concerns were raised that outsourced services may not be subject to the same oversight as government-run services, especially in relation to how well they deliver services for Australian citizens.
2.33
The Australian Council of Social Service (ACOSS) submitted that it is ‘very concerned’ about the outsourcing of Department of Human Services ‘frontline work to private operators’. ACOSS suggested these private operators may not have ‘an acceptable level of expertise’, and reported anecdotal evidence of ‘poor service provision’ by private operators.
2.34
The committee asked the Commonwealth Ombudsman to comment on these concerns. Deputy Ombudsman, Ms Jaala Hinchcliffe explained that the role of the Ombudsman is to provide oversight for Commonwealth departments and agencies and this includes ‘contract service providers where they have entered into a contract with the Commonwealth agencies to deliver services on their behalf’.
2.35
The Ombudsman clarified that it is careful when assessing the quality of service provision by private companies not to publish any information that is ‘protected by legal professional privilege or potentially commercially sensitive’. However, meeting these requirements does not prevent the Ombudsman from publishing its observations and making ‘recommendations that are clear and are able to be implemented by departments’.
2.36
As with its oversight role for government agencies, the Ombudsman confirmed that it does not ‘make binding decisions’ for service providers. Its powers are limited to recommending changes and improvements to service delivery and administration, for which the ministers and departments are then responsible.
Public interest test
2.37
Critics of outsourcing of government services were especially concerned that outsourcing often fails to meet a ‘public interest test’. Dr McLeod expressed the Centre for Policy Development’s view that:
…some areas of human services are so fraught that the public role cannot simply be procurement and contract management…any outsourcing needs to pass a net public interest test to examine, as appropriate, the financial, economic, social and administrative impact, including reputational risks, loss of capability and public accountability.
2.38
PSI argued that outsourcing rarely leads to ‘improved services and efficiency’ as promised, with evidence generally demonstrating that outsourced projects fail to delivery savings or efficiencies. ‘Public sector delivery and management is proven’, PSI said, to be ‘the most efficient modality’.
2.39
Mr Jason Ward, Principal Analyst at the Centre for International Corporate Tax Accountability and Research (CICTAR), drew the committee’s attention to a number of examples from the UK where outsourcing projects had failed to serve the public interest. These included the case of Concentrix, a subsidiary of a US multinational, which was awarded a contract to distribute benefits in the UK. Mr Ward said:
It created such a disaster that the government had to spend tens of millions of pounds cleaning up the mess left behind, and people literally died because of the company's inability to deliver benefits to the recipients that were intended to get benefits. Then the same company ends up getting a contract to do Centrelink services in Australia after a track record of disaster in the UK.
2.40
Mr Ward recommended governments introduce much more thorough vetting of companies seeking to win contracts in Australia.
2.41
The CPSU argued that ‘core government functions like visa processing and areas of social welfare’ should remain the domain of the public service. This is because retaining these services in the public sphere ‘provides accountability and transparency and direct lines through to government’. The CPSU presented the results of a number of community surveys that it believes suggest the Australian public prefers ‘core government services’ to be delivered by the public service.
Economic impacts
2.42
Outsourcing of government services may have impacts on the economy that are unexpected or unforeseen. The CPSU pointed to the loss of jobs that can sometimes be associated with outsourcing projects, and also the possible reduction in wage levels. When government functions are transferred to private entities, the CPSU claimed, ‘the wages that are paid to the workers doing that work invariably drop, and so the economic benefits to the community also drop in concert’. National Secretary, Ms Melissa Donnelly, added:
Essentially, the procurement contract has to have a profit that's taken out of the equation per transaction, and that's money that isn't going to those workers and isn't going to their communities or the local economy.
2.43
The Australian Council of Trade Unions (ACTU) submitted that outsourcing has ‘undermined’ the government’s ability to deliver essential public services, ‘while at the same time forcing workers to accept insecure work and inferior wages and conditions’. In outsourced models of service delivery, ‘subsidies to the for-profit outsourced services end up being larger than the imposition to the budget due to public provision’.
2.44
In relation to the use of casual, non-ongoing and labour hire employees, the Department of Human Services submitted: ‘Non-APS staff arrangements are used as a timely, cost-effective way to complement, not replace, the Department’s current service delivery workforce’.
2.45
Another issue raised by submitters was tax avoidance. CICTAR has studied a number of companies that provide contracted services for government, and found that many exhibit ‘aggressive tax avoidance behaviour’. Mr Ward suggested that Bupa is one such company. He said:
[Bupa] received over half a billion dollars in providing aged-care services, had to reach a settlement with the ATO for $157 million and then, earlier this year, was rewarded with a $3.4 billion contract to provide medical services to the Australian Defence Forces. Companies like this shouldn't be rewarded with public dollars after demonstrating clearly aggressive tax behaviour in Australia and globally.
2.46
Mr Ward acknowledged that the government has taken steps to better assess companies in relation to their tax behaviour. New regulations introduced in 2019 require companies with over $4 million worth of federal government contracts ‘to have a clean bill of health’ from the Australian Taxation Office. However, Mr Ward suggested the new regulations are ‘a fairly weak and ineffective measure’.
2.47
PSI was also concerned about the economic impacts of public money going to companies that exhibit tax avoidant behaviour. Mr Whaites referred to a 2014 case in the UK, where the UK Home Office outsourced visa processing to Dubai-based company VFS, and French company Sopra Steria. According to PSI, VFS was ‘structured through several holding companies located in known tax havens’. Mr Whaites concluded that ‘when finances that would have come to government go to private entities, that money invariably leaves the local economy’.
2.48
Referring to international examples, Mr Whaites explained:
…there has been a significantly increasing number of cases of renationalisation or remunicipalisation, particularly in Europe. The reason why councils, governments and federal governments are doing that is it is cheaper to do so.
2.49
Mr Whaites added that PSI knew of ‘at least 830 cases of remunicipalisation or renationalisation of what were formerly public services’ but stressed that free trade agreements can make it difficult to bring public services back under government control.
Transparency
2.50
A major concern for many submitters was the way in which outsourcing and privatisation can impact transparency. Submitters argued, for instance, that there was not always adequate access to information about government contracts.
2.51
CICTAR recommended that all large contracts should be ‘publicly available and accessible in a database’, unless there is a reason for confidentiality that relates to national security. Mr Ward also argued that freedom of information provisions are ineffective, and ‘it's very difficult to get information around public contracting’.
2.52
Confidentiality clauses in outsourcing contracts were also seen as a barrier to transparency. The Centre for Policy Development’s 2015 report, Grand alibis, called for the Australian National Audit Office to be given the right to review these clauses.
2.53
PSI called for ‘real transparency and accountability in privatised services’, saying commercial-in-confidence provisions prevent this, so ‘the public cannot follow the money’.
2.54
Per Capita reported that it is ‘impossible’ to locate the data required to understand how much public money is spent on engaging temporary staff in relation to outsourced services. However, Per Capita cited data from Austender indicating approximately $750 million was spent in 2016-2017 ‘on temporary personnel’, which ‘represents an almost three-fold increase over the last four years’. Per Capita concluded: ‘Public expenditure, including the engagement of staff to deliver public services, should be fully transparent’.
Automation and robodebt
2.55
Another area of discussion was around the automation of government services, especially automated decision-making processes.
2.56
The Commonwealth Ombudsman was asked if complaints were higher in relation to automated decision-making. Ms Hinchcliffe replied:
We see complaints about issues rather than about whether or not something is automated. But we do see a high number of complaints about the Department of Human Services, and a lot of those complaints do relate to automated data matching. Some of those complaints will relate to difficulty in understanding the system.
2.57
The Ombudsman acknowledged that there are potential benefits to automation, as faster decision-making benefits citizens and ‘large numbers of decisions can be made faster’, potentially saving government resources. However, the Ombudsman also cautioned that ‘particular issues’ need to be taken into account when designing automated decision-making systems.
2.58
To address some of these issues, the Ombudsman reported that it is currently updating ‘a best practice guide on automated decision-making’, which it originally published in 2007.
2.59
The most significant example of automation discussed in submissions to the inquiry was the robodebt scheme, with all submissions received being highly critical of the automated data matching component of the scheme.
2.60
This report does not address robodebt in depth for a number of reasons. Firstly, the scheme is the subject of an ongoing inquiry by the Senate Standing Committees on Community Affairs, which is due report by 25 March 2020. That committee has conducted five public hearings and published 67 submissions and an interim report addressing the scheme in detail.
2.61
Secondly, the Department of Human Services ceased the practice of raising debts based purely on its averaging of Australian Taxation Office income data from 19 November 2020. The department also indicated it would review previous cases.
2.62
Media reports suggest the government changed its position on the use of automated ‘income averaging’ as the sole trigger for issuing debt letters because the practice was not lawful.
2.63
Shortly after the government ceased the practice, the Federal Court ruled in favour of a plaintiff who had challenged a debt raised against her by the department. The judgment said ‘the demand for payment of an alleged debt... was not validly made’, and that a notice issued garnishing the plaintiff’s tax return was ‘not a lawful issued notice’.
Further work on automated decision-making
2.64
The submission from the Australian Human Rights Commission (AHRC) cautioned that:
Evidence is emerging that shows how automated decision making, used in the delivery of social services ranging from social security to child protection, can have the unintended impact of entrenching disadvantage, with a disproportionate negative impact on minority and vulnerable groups.
2.65
The AHRC also revealed that it is conducting consultations as part of a project on human rights and technology. The project is ‘examining the impact of new and emerging technologies using a human rights framework’, and will consider how human rights issues ‘are engaged by the use of AI technologies, and in particular decision making which involves use of AI’.
2.66
ACOSS recommended that, instead of pursuing automated decision-making in the area of debt recovery, the federal government:
convene a roundtable of experts in social security, including people affected, to redesign a fair, accurate and humane system of debt recovery;
cease outsourcing the administration of income support to private operators; and
strengthen the capacity of Centrelink to meet need by increasing permanent staffing levels.
Average Staffing Level cap
2.67
Some submitters suggested that the imposition of the government’s public sector Average Staffing Level (ASL) cap was a driver for privatisation and outsourcing, and that the government should review and/or lift the cap.
2.68
The CSIRO Staff Association submitted evidence of an ‘increased use of external contractors in CSIRO workplaces’ as a result of the ASL cap. The Association recommended an investigation into the CSIRO’s use of external contractors in its application of the ASL cap.
2.69
Disability sector advocates were especially concerned about the impacts of the ASL cap on the performance of the NDIS. People With Disabilities Western Australia submitted:
The staff cap imposed is clearly restricting the NDIA’s ability to respond in a timely manner. This is again impacting on the level of service being received by participants, and in some cases placing them at significant risk.
2.70
The Community and Public Sector Union, Tasmania (PSU Group) submitted that the number of permanent federal public service employees in Tasmania is dropping, with agencies choosing to use ‘labour hire workers’ instead. The PSU Group explained:
Despite a growing population, the number of federal public servants in Tasmania continues to decline. The most recent December 2018 figures from the APS show a decline since December 2013 of 477 jobs in Tasmania or 11%. There are now fewer APS employees in Tasmania than there were in 2007. This decrease has been brought about through redundancies and by agencies not replacing staff who resign.
2.71
The Department of Human Services acknowledged that one of three main drivers for utilising casual, non-ongoing and labour hire employees is ‘the need to operate within the parameters of our budget and Government policies, including the Average Staffing Level (ASL) cap on APS staff’.
Committee view
2.72
The Australian government has a constitutionally-enshrined role and responsibility in delivering essential public services, as outlined in section 51 of the Constitution. These services must be delivered in a way that is fair, consistent, predictable and equitable for all citizens.
2.73
Delivering services efficiently and effectively in an era of advanced technology presents significant challenges. Citizens’ expectations are higher than ever before, and governments must innovate to meet these expectations. Sometimes partnerships with the private sector can form a valuable component of this innovation. But privatisation is not a panacea, and outsourcing government services can cause more problems than it solves.
2.74
Evidence to this inquiry demonstrates that outsourcing government services is an activity fraught with risk. Projects inevitably cost more than originally planned, procurements fail after millions have been invested, service quality frequently suffers and rarely improves, and the profit-drive of private companies often leads to outcomes for citizens that exacerbate inequality, such as the imposition of higher or differential fees for service.
2.75
Privatisation of government service delivery impacts upon jobs and local economies, reducing the number of stable, secure full time jobs around the country. Staff working for private entities are often casual, on contracts, paid lower, and have worse conditions than permanent employees, which leads to greater turn-over in staff and loss of expertise and morale. In addition, privatisation leads to a loss of capability in the public service, sometimes throwing away decades of knowledge and expertise.
2.76
Some government services are not suitable for outsourcing. In particular, services that deal with complex cases, sensitive information and data, highly-vulnerable citizens, or issues of national security may not be suitable for outsourcing. Experiences reported by participants in the NDIS highlight the problems that can occur when private companies administer critical government functions, guided not by the needs of citizens, but by their need to be profitable.
2.77
Evidence to the inquiry also highlighted economic impacts of privatisation that may not be immediately apparent, such as the loss of tax revenues as multinational contract holders avoid paying Australian tax on their profits.
2.78
The committee accepts that the government is ultimately responsible for delivering public services that are fair, equitable and accessible to all citizens. Partnerships with private entities can enhance the government’s capacity to achieve these aims. However, privatisation frequently results in the inverse; leading to inadequate service provision that ultimately costs taxpayers more.
2.79
The committee believes the pendulum has swung too far towards privatisation, and the government would be well-placed to re-prioritise strengthening capacity, and encouraging innovation, within Australia’s public sector.
2.80
The committee believes the Average Staffing Level (ASL) cap has led agencies to use more and more contract labour, ultimately costing the tax-payer more than the cost of equivalent in-house staff. The ASL cap has led to unintended economic outcomes, bolstering the private sector and labour hire companies without improving the budget bottom line. It is an inflexible and arbitrary imposition, and should be lifted.
2.81
The committee was also asked to look at automation, automated decision-making, and the robodebt scheme. The committee chose to not to conduct a detailed analysis of the scheme, as another committee was already doing so.
2.82
The committee appreciates that the practice of issuing debts based solely on automated ‘income averaging’ has now ceased. However, the government must ensure that citizens issued unfairly with debts under the scheme are appropriately compensated as soon as is practicable.
2.83
The committee recommends that the Australian government assess all current and future proposals for outsourcing government services against a ‘public interest test’, which includes flow-on economic and employment impacts. Results of the public interest test, along with a comprehensive business case, must be made publicly-available in a timely fashion.
2.84
The committee recommends that the Australian government provide a commitment that services dealing with complex cases and vulnerable people should not generally be considered suitable for outsourcing.
2.85
The committee recommends that the Australian government, in consultation with relevant stakeholders, implement arrangements to make outsourcing contracts publicly available, unless there are published national security concerns.
2.86
The committee recommends that the Commonwealth public service Average Staffing Level (ASL) cap be lifted immediately.
2.87
The committee recommends that the Australian government ensure any further projects that involve automated decision-making are not pursued if automation reduces service quality, impacts upon fairness, or reduces equity of access.
2.88
The committee recommends that Commonwealth departments and agencies have regard to the Commonwealth Ombudsman’s guidance on best-practice in automation at the earliest stages of any relevant project.