Australian Journal of Public Administration, vol. 77, no. 3, pp. 492–499 doi:10.1111/1467-8500.

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Practice Insights

‘Utterly Disgraceful’: Social Media

and the Workplace

Alison Barnes and Nikola Balnave

Macquarie University

Peter Holland
Monash University

Social media use by Australian public servants has given rise to questions pertaining to their
political rights, impartiality and privacy outside of work. Drawing on the recent case Starr
v Department of Human Services these issues are explored. The findings suggest that social
media use has heightened tensions around public servant’s rights to comment on issues of
the day, and its use by employees both inside and beyond the workplace remains contested
terrain.
Key words: social media, public servants, impartiality, codes of conduct, law

Introduction This paper examines these contentious issues

Social media, including social networking web-
sites (Facebook, Google+, LinkedIn, and Twit-
ter) and online blogs (Sensis, 2017) has gen-
erated a range of employment law issues often
related to the contested terrain between an em-
ployee’s work and private lives (Forsyth 2014:
8). It can also augment the reach and impact of
employee commentary about work issues and
may cause an employer to heighten surveillance
of non-work conduct both inside and outside
the workplace.
Social media has also thrown into sharp re-
lief the unique role of the public service in
Australian culture. Unlike many other parts of
the labour force, social media’s use by Aus-
tralian public servants has brought to the fore
questions about balancing the purported inde-
pendence of the public service against a public
servant’s right as an individual to engage with
the politics and issues of the day.
in the context of a recent high-profile case –
Starr v Department of Human Services (2016)
FWC 1460 (29 March 2016) that has arguably
added more uncertainty than clarity to the de-
bate about the role and impact of social media
on workplace policies and practices. To frame
the case contextually, the paper first explores
the issue of social media and work in general,
and in the public sector specifically. It then
details the Starr case and analyses the implica-
tions of the decision. The findings of the case
suggest that codes of conduct, while necessary
to set boundaries, can be intrusive and generate
the workplace conflict they seek to head off. For
public servants social media use can be partic-
ularly problematic and raises many questions
about the conflict between impartiality and po-
litical participation, and just how the public in-
terest is best served.
Social Media and the Workplace

Sally-Anne Fitzgerald v Diana Smith T/A Es-

Accepted for publication: January 29, 2018 cape Hair Design (2010) became the first


C 2018 Institute of Public Administration Australia
 Barnes, Balnave and Holland
major case in Australia to focus on the in-
teraction between the employment relationship
and social media. The case involved an em-
ployee who had been dismissed for her com-
ments about her employment on her social me-
dia account. Although the setting of Fitzgerald’s
Facebook page was on private (which meant the
comments were only to friends) and the salon
was not named, the salon owner was alerted to
the remarks and dismissed the employee be-
cause of them. The employer was found to
have no valid reason for the dismissal, but it
was Commissioner Bissett’s observations that
framed the relationship between social media
and workplace relations. Noting that social net-
working sites were increasingly places for dis-
affected employees to vent about workplace is-
sues and that comments may become public,
Commissioner Bissett stated that:
A Facebook posting, while initially undertaken
outside working hours, could lead to dismissal if
it breaches an express term of the employment
contract . . . It would be foolish of employees to
think that they may say as they wish on their
Facebook page with total immunity from the con-
sequences (Bissett, cited in Workplace Express
2010).
This statement clearly articulated that em-
ployees are on notice for their conduct on so-
cial media and for any remarks they make about
their employment whether they are at work or
not. Bissett’s comments appeared to have set the
tone for how social media use and the employ-
ment relationship is viewed in Australia (see
Forsyth 2014; Thornthwaite 2017), although
more recent decisions by the Commission in-
dicate a return to some distinction between the
public and private lives of employees (Thorn-
thwaite 2017), However, the boundaries remain
ill-defined, and blur all the more in the case of
employees of the public service.
Social Media and the Public Service
Public service impartiality is seen as one of the
hallmarks of the Westminster system (Aucion
2012). This impartiality has come into ques-
tion in recent years as firstly, public servants
have come under more pressure to defend pub-
493
lic policy (Grube and Howard 2016), and sec-
ondly because they may wish to comment on
their workplace or public policy. The speed and
reach of social media has reignited the debate
around the perceived expectation of political
impartiality of public servants (APS Making
Public Comment, p. 37). Australian federal and
state public services employ nearly two million
people (Australian Bureau of Statistics (ABS)
2016). Since its inception there has been de-
bate about the extent to which public servants
should, in their capacity as private citizens, be
able to engage with the ‘politics’ of the day.
The discussion stems from the belief that, to
perform effectively and maintain public confi-
dence, public servants should be, and be seen
to be, impartial, and that impartiality per se is
central to the public interest. As former Aus-
tralian Public Service Commissioner Stephen
Sedgwick wrote in response to an editorial crit-
icising social media policy; ‘This value gives
Parliament and the public confidence that pub-
lic servants will serve faithfully the government
of the day and deliver government programs to
the community professionally, irrespective of
their own views and beliefs about them’ (Sedg-
wick 2014).
The political rights and conduct of public
servants have been more tightly controlled than
those of other Australian employees. This is not
a recent development; in Australia it stems back
to ‘The Public Service Act 1902 which allowed
for the dismissal of officers for “any disgrace-
ful or improper conduct”’ (Australian Public
Service Commission (APSC) 2016). Nor is it
only with the emergence of social media that
we see the lengths to which management are
seemingly prepared to go to discipline public
servants who comment on government activi-
ties. Indeed, this has been the case with more
conventional forms of media such as newspa-
pers, radio, and television. For example, in 2013
Paul Parker, a NSW Department of Primary
Industries public servant of 45 years standing,
commented in a local newspaper, The Young
Witness (circulation 2400), that $30 million
cuts to funding of agricultural support would
potentially result in the loss of 250 jobs (300
jobs were in fact lost). Parker was reprimanded
by the state’s third most powerful public

C 2018 Institute of Public Administration Australia
494 Utterly Disgraceful
servant and, at the behest of the NSW govern-
ment, investigated by two former federal police
officers who suggested he be referred to the
ICAC (Independent Commission Against Cor-
ruption) for receiving free copies of the Young
Witness (Parker had received free copies of the
newspaper in return for the paper using pho-
tographs he had taken of local sports). Parker
was found to have contravened three sections
of the Public Sector Employment and Manage-
ment Act but was not dismissed, although he
subsequently resigned because of his treatment
(Aston 2013). When the relevant Shadow Min-
ister asked for the documents relating to the
investigation, the government objected to the
order on the grounds of advice from the Depart-
ment of Primary Industries that the documents
contained sensitive information and releasing
them would breach privacy and confidentiality
requirements (The Young Witness 2013).
The federal government’s recent debt recov-
ery system – the so-called ‘Robo-debt’ – raises
similar issues and highlight concerns about
legitimate public interest, apprehensions that
are reinforced by apparent attempts to silence
public servants via disciplinary threats, includ-
ing criminal prosecutions, against employees
who comment to the media about the debt re-
covery system (Towell 2017a). Federal inde-
pendent MP Andrew Wilkie declared that the
Commonwealth Public Service was trying to
‘bully’ Centrelink employees into staying silent
on the issue, noting that ‘There is no doubt
that the Centrelink debt recovery program has
reached the point of high farce, and I don’t
doubt that both the government and, by direc-
tion senior Centrelink management, are now
pulling out all stops to try and silence the
workers tasked with carrying out the program’
(Towell 2017b).
Although tensions regarding the political
rights of public servants, and disciplinary ac-
tion undertaken by management, have been on-
going, developments in social media technolo-
gies have made these concerns more prominent
and acute. The APSC, in a discussion paper
inviting public comment, noted that ‘Until rel-
atively recently in the history of the Australian
Public Service . . . restrictions on public
comment by APS employees was a largely
September 2018
theoretical concern. In an era where public
comment was mostly limited to letters to the
editor and submissions to Parliament, issues
of partiality arose infrequently’ (APSC 2016).
The Community and Public Sector Union
(CPSU), in response to the paper, observed
that ‘emerging social media platforms have
allowed commonwealth agencies and their
employees new and unforeseen opportunities
to engage not only with their stakeholders, but
also with one another and the community at
large’ (CPSU 2016).
There have also been several high-profile
cases, such as Banerji v Bowles (2013)
highlighting these concerns. Public servant
Michaela Banerji, under the alias La Legale,
tweeted comments critical of Australia’s
refugee policy and her manager, but gave no
indication to her followers that she was a pub-
lic servant. Banerji was, however, dismissed
because her comments ‘created the perception
she could not work impartially’ (Public Eye
2013). The case raised questions as to how
management identified her (Australian Broad-
casting Corporation (ABC) 2016) and what
constitutes impartiality: ‘One might wonder if
the internal investigation, which resulted in the
Department uncovering @lalegale as Banerji’s
account, would have been conducted had her
tweets been praiseworthy rather than critical’
(Joseph 2013). Joseph argues that the case sug-
gests the government was more interested in
punishing those critical of it and its policies
rather than the expression of a view, and that is
at the nub of the problem (Joseph 2013). One
could conclude that it is the type of impartiality
rather than impartiality in and of itself that gov-
ernment and public service management find
problematic.
In a further case, Bernard Gaynore, an Aus-
tralian Defence Force (ADF) reservist, was
dismissed in 2014 for homophobic and anti-
Islamic comments made in a private capac-
ity on social media. The ADF argued that his
remarks undermined policies and attempts to
build diversity and harmony across the armed
forces. The Federal court subsequently over-
turned Gaynore’s dismissal on the grounds of
implied protection of political communication.
Examples such as these prompted the APSC

C 2018 Institute of Public Administration Australia
 Barnes, Balnave and Holland
to call for comment on issues such as the role
of public servants ‘commenting publicly on all
political issues, or only those that relate to their
agency’s work’; ‘whether the rules should differ
for different types of employees (such as tighter
limits on senior executives)’ (Mannheim 2016)
or those with specific duties such as spokespeo-
ple or those who work for the electoral commis-
sion (CPSU 2016).
Other issues of freedom of speech or a public
servant’s capacity to engage with the issues of
the day as a private citizen have drawn atten-
tion to the content and manner in which public
service codes of conduct have been used to dis-
cipline public servants. The paradox here lies
in the fact that research indicates that there are
several universal or core values that frame a co-
hesive code of conduct and these include, hon-
esty, integrity, responsibility or duty of care,
and fairness (Schwartz 2002; Schwartz et al.
2005). A key theme within the criteria is that
the code takes account of all stakeholders. As
such, this approach to decision making forces
senior management to consider all stakeholder
perspectives in the decision-making process.
These cases raise issues of freedom of speech
and a public servant’s capacity to engage with
the issues of the day as a private citizen and in
line with the core values of a code of conduct
acknowledging all stakeholders to the public
service. As the following case demonstrates,
although codes of conduct provide guidance as
to how employees should conduct themselves
online, in not taking account of all stakeholders,
they may be too restrictive and thus potentially
undermine the ability of Australia’s nearly two
million public servants to engage in public de-
bates even when it is in the public interest that
they do so. It also brings into critical focus the
role of government and the lengths to which it
will go to silence such voices.
Starr v Department of Human Services
Mr Daniel Starr, a Centrelink employee for over
20 years, was dismissed in 2015 for posting un-
der an alias what management considered in-
appropriate messages and comments about the
Department of Human Services’ (DHS) poli-
495
cies and practices and its clients. The state-
ments were deemed to contravene the depart-
ment’s social media policy, which stated that,
although employees have the right to make pub-
lic comment, it must be in a private capacity
as a member of the community rather than as
a departmental employee. Moreover, the em-
ployee’s comments are not to bring the de-
partment into disrepute (FWC 1460, 29 March
2016).
The subsequent investigation and evidence,
which led to Starr’s dismissal, showed that he
had involved himself in chat forums, and of-
ten clarified DHS (government) policy or was
critical of the lack of funding and resources to
work effectively. Statements by colleagues and
a supervisor indicated that Starr was a good and
hardworking employee who undertook a men-
toring role with junior staff. Notwithstanding
this, DHS management argued that Mr Starr
had breached Australian Public Sector (APS)
values by making public comments that:
r Criticised the government.
r Encouraged members of the public to
complain to their local member of parlia-
ment about the services of the department.
r Were critical of the department’s policies
and programs.
r Criticised ‘Managers’ and more broadly,
the administration of the department.
r Disclosed non-publicly available informa-
tion about delays in processing payments.
r Berated fellow employees (notably
‘Flick’, a member of the Social Media
team, and others), by calling some of
them ‘utterly useless’ and saying they
‘couldn’t get a job anywhere else’.
r Disrespected customers of the depart-
ment, including referring to them as ‘spas-
tics and junkies’ (FWC 1460, 29 March
2016).
It is, however, instructive to consider the
lengths to which the department went to iden-
tify the source of anonymous posts on social
media that were made in the person’s own time,
which often defended as well criticised the de-
partment, but also made derogatory comments

C 2018 Institute of Public Administration Australia
496 Utterly Disgraceful
about DHS clients (which the department did
not originally appear to consider to be an issue).
The Business Integrity Office (BIO) of the
DHS undertook the investigation. The evidence
produced in court indicated that the BIO had
trawled through thousands of posts from the
previous decade using comments about phys-
ical locations in the relevant area and details
of holidays or other times when absent from
work to create a geographic profile, by which
BIO was able to identify and subsequently dis-
miss the employee, who then lodged a claim of
unfair dismissal. The extensive search under-
taken highlights not only the lengths the DHS
was prepared to go to to arguably stifle debate
and criticism of itself but also the propriety of
using taxpayer funds to in effect suppress infor-
mation that was arguably in the public interest.
Starr acknowledged that he would have re-
ceived the Department’s social media policy
but did not recall reading it. In addition, he said
that he was unaware that he could not criticise
government policy. (It is worth noting that in
accordance with the policy, Starr had acted as
a private person.) Following the investigation,
Starr stated that:
r He was sincerely remorseful for his ac-
tions.
r He agreed that a number of the comments
he had made were entirely inappropriate
and unacceptable.
r He did not set out to intentionally cause
harm to the Department.
r He offered advice online because he was
naı̈ve about the Social Media Policy and
had a passion and desire to assist people.
r He did not sign up to the forums for the
purpose of making negative comments
about the department, but had participated
in them for many years with the same user
name.
r There was no excuse for making deroga-
tory comments such as ‘spastic and
junkies’ about customers of the depart-
ment. He took full responsibility for this,
recognised they were completely and ut-
terly inappropriate, and there was no jus-
tification for his making them.
September 2018
r The information he had disclosed was the
same information that he and his col-
leagues relayed to customers on a daily
basis.
r He understood it to be the usual practice
that dissatisfied customers were to be told
to complain to members of parliament.
r He had always treated customers with re-
spect at work and had always acted with
professionalism and integrity.
r He had long suffered from depression and
anxiety and sometimes engaged in self-
destructive behaviour as a coping mech-
anism. Some of his comments on forums
involved him releasing his internal anger
and frustration.
r He accepted that he should be subject to
a sanction for his behaviour, but not dis-
missal (FWC 1460, 29 March 2016).
In his findings, Vice President Hatcher noted
that the activity occurred outside work (as in
the Fitzgerald case), which meant that it was
necessary to identify the regulation of ‘out-of-
hours’ conduct. Using the criteria outlined in
the benchmark case, Rose v Telstra Corpora-
tion Limited (1998), Vice President Hatcher
sought to establish whether Starr’s comments
had seriously damaged the employer’s business.
In addition, he noted that, without curbing the
constitutional right of free speech, the case of
McManus v Scott-Charlton (1996) recognised
that the scope of control over public servants
whose employment is regulated by statute may
be greater than that applying in the private sec-
tor.
Vice President Hatcher dismissed several of
the department’s claims regarding political un-
dertones and damaging of the business per se,
but he did state that Starr’s comments referring
to clients as ‘spastics and junkies’ and describ-
ing the way in which the department was run as
‘utterly disgraceful’ were legitimate instances
of misconduct. In the context of the decision to
dismiss Starr, however, Vice President Hatcher
found that the dismissal was disproportionate
to the misconduct when contextual factors such
as the length and quality of his service and his
genuine remorse were taken into account, and
he ordered Starr’s reinstatement.

C 2018 Institute of Public Administration Australia
 Barnes, Balnave and Holland
Discussion
Starr was reinstated, but the sanction for his
misconduct was his loss of remuneration for the
period he was not at work. In echoing the state-
ment of Commissioner Bissett in 2010 about
out-of-hours use of social media outside work
to comment about the employer (Fitzgerald v
Dianna Smith t/a Escape Hair Design), Vice
President Hatcher stated: ‘It will also serve as a
signal to him, other employees and the Depart-
ment and the Public that conduct of the type he
engaged in is unacceptable and not condoned
by the Commission.’
Despite findings for the employee in both
cases, it is interesting that both commissioners
stated that it was unacceptable for employees
to post comments about their work. In Starr’s
case, the Commissioner held that it was also un-
acceptable to make derogatory and demeaning
comments about clients. Interestingly the core
issues that could be regarded as in the public
interest within the frame of reference of a more
robust code of conduct were not seen as an is-
sue. What appears to be an important element
in both cases appears to have been context. Is-
sues associated with frustration at limited re-
sources that impeded the ability to work effec-
tively, a lack of intentional malice, and genuine
remorse were factors taken into account by the
Commissioner.
It is also worth reflecting on the lengths to
which the DHS was prepared to go to locate and
dismiss Daniel Starr for what the court deemed
to be minor indiscretions. In view of the time,
effort, and stratagems dedicated by the DHS
to identifying Starr, the accuracy of whose re-
marks about the department have not been chal-
lenged by DHS, it is clear that its efforts are an-
tithetical, not only to the rights of privacy and
of free speech, but also to the legitimate public
interest, and are arguably aimed at stifling in-
formed commentary on its activities by public
servants, which would not be considered in a
code of conduct that reflected a greater appre-
ciation of the stakeholders. Because the Starr
case does go some way to re-establishing the
boundaries between work and private activity
and, perhaps more importantly, provides public
servants with limited protections, DHS lodged
497
an appeal in April 2016. This appeal appears
now to have been dropped possibly because of
the resources already dedicated to a case that
the Commissioner noted to be one of minor
indiscretions.
The Starr case and those like it give rise
to questions worthy of future research such
as to whom such tight restrictions on polit-
ical engagement should apply. Should non-
managerial rank and file public servants who,
as Wilson (ABC 2016) notes, are unlikely to
derail government, be subject to the same re-
strictions as heads of an agency or senior diplo-
mats? Cases such as Parker, Banerji, and Starr
demonstrate the lengths that Australian govern-
ments appear to go to identify public servants
who raise concerns about government policies
and procedures or cuts to funding. They raise
questions about the appropriate use of public
money and what, in this era of fake news and
alternative facts, we consider to be the pub-
lic interest, which goes to the heart of an ap-
propriate code of conduct. These cases raise
the issues pertaining to employer responsibil-
ity including whether employers should address
these matters providing adequate staff train-
ing and counselling rather than simply rely-
ing on policy and codes of conduct statements
or dismissing employees frustrated with their
working conditions. Alternatively, in an era of
ubiquitous e-communications, should it be as-
sumed that employees are aware of the poten-
tial impact of their comments and adhere to
a policy of not putting something on social
media that they are not prepared to stand in
the middle of the office and say. On the other
hand, does the emphasis on self-censorship cur-
tail employees’ rights to freedom of speech
and privacy outside of the workplace? Finally,
does social media use by public servants to
comment on issues that may be considered
to be in the public interest require the de-
velopment of more effective whistleblowing
legislation?
As they stand, public service social me-
dia codes of conduct, rather than serving to
maintain public confidence, may be working
not only against individual privacy but also
against the public interest. In light of the im-
pact of funding cuts on the DHS, for whom

C 2018 Institute of Public Administration Australia
498 Utterly Disgraceful
Starr worked, evidence of the Department’s de-
liberate provision of misinformation about in-
creased processing times and the effect on vul-
nerable people, can the potential for codes of
conduct to lead to the suppression of this in-
formation be said to be in the public inter-
est? Social media provides a means for peo-
ple to inform political debate or to lay bare
the workings of government. The most recent
controversy surrounding Centrelink’s ‘Robo’
debt recovery activities is another salient re-
minder of the ongoing relevance of these
questions.
Conclusion
This paper has highlighted the problems,
issues, and complexity surrounding the use of
social media and the (public sector) workplace
and managerial responses to them. An em-
ployee’s right to freedom of speech and privacy
outside the work environment must also be
considered. The unique situation of the public
service puts these tensions into sharp relief: the
striking of a balance between the employer’s
legal obligations and the employee’s rights,
and for the public service to be seen to act
impartially, is extraordinarily complex and
difficult when it comes to developing social
media policies. As this case study has illus-
trated, there remains significant debate within
the workplace and the judiciary about this
issue. The danger, as noted above, is that policy
obligations and processes to control such com-
munications that are too dogmatically defined
can easily conflict with both procedural and
employee fairness and the public interest. It
is hoped that forward-thinking managers will
see the impracticality of dogmatic approaches
to social media use and focus instead on the
development of a broader range of practices
such as education and training to facilitate
a better understanding of the issues and
thereby a better working relationship, as well
as a broader approach to stakeholders when
considering codes of conduct. However, new
public sector social media policy guidelines
have been roundly criticised (McIIroy 2017).
Whatever the outcome, it is clear that social
September 2018
media use in the workplace remains contested
terrain.
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