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Circular 2013/10: Guidance for agencies on managing cyber-bullying of APS employees by members of the public


This circular attaches guidance for Australian Public Service (APS) agencies to help them manage situations in which APS employees may be subject to cyber-bullying by agency clients or other members of the public.


Cyber-bullying is an emerging issue for APS employees, associated with increasing use of social media and other online networking tools. From time to time, clients and other members of the community criticise agencies online because they are dissatisfied with agency services or the administration of government policy. Sometimes, however, the online comments that they make are directed personally at APS employees, and can include comments that are distressing to the employees involved.

Cyber-bullying is potentially a work health and safety, security, and reputational issue for APS agencies. Agencies have an obligation to protect the health and safety, including the psychological health and safety, of their employees. The Work Health and Safety Act 2011 requires a proactive approach to the management of risk and the exercise of due diligence so that agencies can meet their duty of care to employees.

Cyber-bullying is a complex issue. Local managers may require assistance and advice from a range of agency specialists, including IT, web services, people management, legal services, and security, to manage cyber-bullying incidents effectively.


The attached guidance deals only with cyber-bullying by members of the public—not by APS employees. Harassment, including online, by APS employees should be managed in accordance with an agency’s policies on bullying and harassment, or other unacceptable workplace behaviour, and, where appropriate, the agency’s procedures for investigating suspected misconduct.

While the incidence of cyber-bullying is small, it can have a significant impact on the people affected by it. It is therefore important that agencies consider the need for a strategy to minimise the risk of cyber-bullying of their employees and respond effectively to incidents as they arise. The guidance is intended to help agencies to:

  • develop strategies to manage the risk of cyber-bullying, consistent with the APS Values and Employment Principles, and
  • manage instances of cyber-bullying, including providing appropriate support to employees who become the targets of online abuse.

This guidance may be used in conjunction with an agency’s policies and procedures on harassment and bullying, social media, dealing with difficult clients or customer aggression, risk management, and/or other relevant guidance, and may be used to inform agencies’ internal policies and procedures on cyber-bullying.


While the Commission has co-ordinated the preparation of this guidance, which spans the policy responsibilities of a range of APS agencies, its development has been informed by the practical experience of agencies. The Commission thanks the members of the Working Group on Cyber-bullying of APS employees by clients for their cooperation and support. Agencies involved in the Working Group were: Comcare; the Department of Human Services; the Department of Veterans’ Affairs; the Office of the Australian Information Commissioner; the Office of the Commonwealth Ombudsman; Screen Australia; and the then Departments of Education, Employment and Workplace Relations; and Finance and Deregulation.

The Commission would also like to thank the Attorney-General’s Department; the Australian Federal Police; the Department of Foreign Affairs and Trade; the then Departments of Broadband, Communications and Digital Economy; Families, Housing and Community Services and Indigenous Affairs; Health and Ageing; Immigration and Citizenship; Regional Australia, Local Government, Arts and Sport; and Sustainability, Environment, Water, Population and Communities for their support and feedback.

Finally, the Commission would like to extend particular thanks to the New South Wales Ombudsman’s Office for allowing the Commission to use Chapter 21 and Appendix 9 of its Managing Unreasonable Complainant Conduct Practice Manual (2nd Edition, 2012) in preparing and adapting this guidance material for the APS.

Further information

Please contact the Ethics Advisory Service by phone on (02) 6202 3737 or by email at ethics [at] apsc.gov.au if this circular requires clarification or further information is required. The Ethics Advisory Service is a telephone and email inquiry line available to APS employees, managers and agency heads to assist agencies in managing ethical and other issues relating to the APS Values and Code of Conduct.

Information about APS employees’ obligations when making public comment and participating online, in the context of the APS Values and the Code of Conduct, is available in Circular 2012/1: Revisions to the Commission’s guidance on making public comment and participating online.

This guidance will be incorporated into existing Australian Public Service Commission publications and guidance when they are updated in the near future to take account of amendments to the Public Service Act 1999. These publications include Respect: promoting a culture free from harassment and bullying in the APS and APS Values and Code of Conduct in Practice: a guide to official conduct for APS employees and agency heads.


Sarah Dinning

A/g Group Manager, Ethics

17 October 2013

Last reviewed: 
29 March 2018