Yes, I think it clearly is much more straightforward for that billboard or a newspaper ad that's a stand-alone thing. It does seem to be a little more complicated in the digital universe.
When Mr. Whalen initially asked about this, the answer I heard was that, yes, these rules do apply to government websites. It sounds like they don't, or maybe they can't, in the case of prohibiting the name, voice, and image of a minister.