Government Files is The Canada Report’s public-records analysis series examining government documents obtained through Canada’s Access to Information (ATI) and provincial Freedom of Information (FOI) laws. These transparency laws allow members of the public to request internal government records from federal and provincial institutions. This article reviews documents released through those processes and summarizes what the records contain and what they show. While we strive for accuracy, this article represents an analysis and interpretation of the source material. For complete accuracy and full context, readers should review the original documents, which are available in full below.
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Introduction
British Columbia's government quietly contributed half a million dollars to ICBC's advertising campaign promoting Enhanced Care, pushing the total marketing budget to $3.3 million in early 2021. Internal emails obtained through a Freedom of Information request reveal not only the financial details of the campaign but also government concerns about how the public insurer was portraying its controversial insurance reforms.
The documents show a carefully managed rollout where government officials vetted ICBC's advertising spending, approved responses to media inquiries, and even flagged concerns about the facial expressions of actors used in promotional materials.
What the Documents Show
The records contain email exchanges between officials at BC's Ministry of Public Safety and Solicitor General, ICBC staff, and government communications personnel from January through March 2021. The correspondence reveals details about advertising budgets, media inquiries, website imagery decisions, and the approval process for public communications about Enhanced Care.
ICBC's spring advertising campaign for Enhanced Care ran from January to May 2021, covering radio, television, and digital media including Facebook, Instagram, Twitter, and digital billboards. The campaign required approval from Government Communications and Public Engagement headquarters for any questions about budget allocations.
The Budget Details
ICBC allocated approximately $2.8 million for the Enhanced Care advertising campaign in early 2021, representing 1.7 percent of the total Enhanced Care project budget. However, this wasn't the full story. The provincial government contributed an additional $500,000, bringing the total campaign budget to $3.3 million.
The spending breakdown provided to media outlets in March 2021 showed television advertising received the largest allocation at $571,800, followed by radio at $418,500. Digital spending was distributed across multiple platforms: billboards received $269,140, online video $294,000, banner ads $218,000, social media $123,000, and Google AdWords $135,000. Smaller amounts went to online audio at $40,000.
ICBC worked with PSDDB for creative services and Vizeum for media buying. The campaign aimed to inform British Columbians about what the ministry described as "the biggest change to auto insurance in our province's history."
Year-Over-Year Comparison
The 2021 campaign represented a substantial increase from the previous year. In 2020, when Enhanced Care launched in February, ICBC spent roughly $1.67 million on advertising through the end of the year. That spending represented 1.9 percent of the project budget as of December 31, 2020. The provincial government also contributed $780,000 that year, bringing the total 2020 budget to $1.75 million.
The increase in spending between 2020 and 2021 suggests ICBC and the provincial government viewed continued public education about Enhanced Care as essential even after the initial launch period.
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Government Concerns About Website Imagery
One of the more revealing aspects of the documents involves internal concerns about how ICBC was visually representing Enhanced Care to the public. In late January 2021, government communications officials flagged issues with the facial expressions of people featured on the Enhanced Care microsite.
Nammi Poorooshasb from Government Communications and Public Engagement wrote to ICBC staff noting that feedback from a few people indicated "the stunned or confused faces selected for the website don't echo the sense of confidence and improvements to ICBC." She acknowledged that people unfamiliar with the site who came through advertising might be "perplexed by the disappointed or confused looks in the images."
Poorooshasb raised the concern that this could become an issue with the minister and suggested reviewing all captured footage to find images that "evoke a bit more warmth." ICBC responded by changing the imagery, featuring a character named Alvin on the microsite homepage and a new image of someone named Candus smiling on the Care and Coverage page.
This exchange reveals the level of attention government officials paid to public perception of Enhanced Care, including details as specific as the facial expressions of actors in promotional materials.
The Estimator Tool Investment
The documents also reveal that ICBC spent approximately $600,000 upgrading its online estimator tool to support the Enhanced Care transition. This investment came from ICBC's optional insurance revenue rather than basic insurance rates.
An internal memo prepared for potential media questions noted that ICBC first launched its estimator tool in 2019, and the Enhanced Care upgrades added functionality allowing customers to assess how coverage changes and deductible limits would affect their insurance premium. The tool also showed customers their estimated Enhanced Care refund eligibility, provided options for email and banking details, and improved performance to handle more concurrent users.
The tool attracted significant interest, receiving more than 70,000 visits in its first week after launch in late January 2021. Government officials cited this as confirmation that "customers are interested in using it to see what their next renewal looks like and how much they'll save under Enhanced Care."
Media Management
The documents show multiple media inquiries about the Enhanced Care advertising campaign, all of which required government approval before ICBC could respond. Bob Mackin from The Breaker requested details about the approved budget, schedule, suppliers, creative agency, and media buying company for "seven different Enhanced Care TV and web spots."
Tanya Boguski from CTV News asked whether the commercials were shot and produced in British Columbia and whether the actors were BC-based. Colin Dacre from Castanet in Penticton inquired about advertising practices and how ICBC's advertising spending for no-fault insurance was dispersed across TV, radio, and social media.
In each case, government communications staff prepared recommended responses and sought approval from multiple officials before allowing ICBC to respond. This demonstrates the degree of control the provincial government maintained over public communications about Enhanced Care, despite ICBC's status as a Crown corporation with its own communications capacity.
What's Not in the Documents
The records do not explain the criteria used to determine what portion of Enhanced Care costs should be funded by ICBC versus direct provincial government contributions. The distinction matters because ICBC's spending ultimately comes from ratepayers through insurance premiums, while direct government contributions come from general tax revenue.
The documents also don't reveal the total Enhanced Care project budget, only that advertising represented 1.7 percent of it. This makes it impossible to calculate the full scope of implementation costs for the insurance reform.
Additionally, while the records show extensive government oversight of ICBC's communications, they don't clarify the formal authority structure governing this relationship or whether this level of political control over Crown corporation communications is standard practice.
Implications
The documents raise questions about the appropriate relationship between provincial governments and Crown corporations. While ICBC operates as a government-owned insurer, the level of oversight demonstrated in these records suggests the provincial government treated Enhanced Care communications as a government initiative rather than a corporate decision by an arms-length entity.
The provincial government's decision to supplement ICBC's advertising budget with direct funding is particularly notable. This approach effectively allowed the government to promote a policy initiative while having much of the cost appear on ICBC's books rather than in ministry budgets subject to legislative scrutiny.
For British Columbians, the records provide transparency into how public money was spent promoting Enhanced Care. The $3.3 million campaign represents a significant investment in public education about insurance reforms, but also reflects the government's assessment that substantial marketing was necessary to explain and build support for the changes.
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Support Government FilesAll information referenced is from the Ministry of Public Safety and Solicitor General, request number PSS-2021-10941, obtained through Freedom of Information requests. The records contain internal emails and briefing materials regarding ICBC's Enhanced Care advertising campaign from January through March 2021.
