How sure are you that your approach to risk management and communication will actually work?

Our experience and research suggest that many approaches won’t work, particularly those based on academic communication research. The reasons for this are complex, involving outmoded ways of thinking and a lack of appropriate skills. But the resultant breakdowns in communication are obvious: information is ignored, cannot be found, or is not understood.

As the old saying goes, a chain is only as strong as the weakest link, and in risk management, communication is often the weakest link. Unfortunately, you won’t know that it hasn’t worked till it’s too late. And it probably will not work unless the communication is developed to the highest standards using the most advanced thinking.

The challenge facing many organisations is that they do not know what a high standard of communication is, and they do not know how to measure their own communication efforts to make sure it achieves a high standard. This is not just a challenge in risk management; it permeates many aspects of organisational policy and practice.

Fortunately, it doesn’t have to be that way. The methods for getting communication right are now understood, though not yet widely available. Our job is to make those methods available to our Members.

In fact, over the last few years we have helped over 200 of our Members investigate, develop, and implement risk management and communication policies and practices that really work.

Join us, and find out how.

Thank you Mister Prime Minister!

It’s not often I feel grateful to politicians, but today I make an exception.

My gratitude may come as a surprise to most readers of this blog. And if your’e Australian, you might be doubly surprised because our current Prime Minister is controversially spending nearly $40 million dollars of our money on a public information campaign to persuade us that he is acting in our interest—raising taxes to make Australia a better place.

You might also be surprised that my gratitude is related to a public information campaign. After all, we at CRI have been highly critical of such activity in the past; if you look through many of our publications you will find a sustained attack on this type of information and communication activity. From that point of view, the current campaign is no different to most other such campaigns, with the usual litany of false assumptions, poor research methods, inane execution, and dubious outcomes. Indeed looking at this particular campaign fills me with a sense of great weariness at the thought of the many layers of poor thinking and execution that one would have to strip away before one might get to a position in which one could do something useful.

The irony is that to do something useful in this area—to explain the new tax reforms and their impact and to have these explanations widely available—would cost a tiny fraction of what the government is currently spending. My back-of-the-envelope calculation gives a figure of 5% of the current budget, about $190,000. BTW, this includes the costs of research.

So, why am I grateful to the Prime Minister? Clearly, not for spending my money wisely. I will explain.

Most days I avoid reading newspapers. It’s depressing and not very rewarding: a bland mixture of disaster, death, and nitpicking commentary. But every now and then the desire to be in touch, the habit of reading the paper with a cup of coffee in hand, comes upon me. Sadly, the habit is accompanied by guilt: if I avoid reading something I know I should read but know I won’t enjoy, I feel guilty, torn between duty and dislike.

So imagine my delight this morning when I came across one full newspaper page that I knew I wouldn’t have to read, one I could bypass yet still do my duty. That full page was so clearly a government public information campaign advertisement, I knew at first glance that I could skip it. No obligation, no duty and no guilt.

So, thank you Mister Prime Minister. You made my day!

As the old saying goes, nothing is more certain than death and taxes. In the contemporary Australian debate about taxation we can add that nothing is more certain than tax and complexity. The reasons for this are many, but the primary reason is the process by which taxation rules and regulation get designed and passed into law and administrative practice.

No tax law, however well drafted by parliamentary draftsmen, escapes the parliamentary process of amendment, with all the resultant legal and administrative complexity. This is the reality of most laws passed through a bicameral party-based system. One could argue that this is democracy at work, with all its attendant checks and balances. But checks and balances mean complexity in law and administration.

Much has been said, in the current debate and in the lead-up to the Henry review of taxation, about simplification of the system. In the face of the obvious and avoidable reasons for complexity this is worrying, as if attempts to simplify the law will necessarily lead to a simpler system. The complexity is there to stay in one form or another.

Thus the primary question should be: Who should manage the complexity? In the case of our current taxation system, the Australia Taxation Office (ATO) has outsourced the complexity: an army of accountants, book-keepers, tax consultants, the poor—who cannot afford these services—and a few DIY enthusiasts now manage the complexity and administration of the country’s tax system.

The ATO has always outsourced complexity, but since the introduction of what is euphemistically called ‘self assessment’ in the late 1980s, this outsourcing of complexity has become a positive policy. The Tax Pack was one of the earliest high profile public manifestations of ‘self assessment’, BAS statements are a more recent high profile example. The consequence of these and many other less obvious examples have progressively externalised the complexity of the system.

Some work could be done to simplify such things as the Tax Pack and BAS, but only at the margins. It is the fact of these instruments that constitutes the complexity; real reform can only occur by removing them. In other words, the complexity needs to be managed by the ATO on behalf of the taxpayers.

For this to happen, the ATO would have to be a much larger organisation, properly resourced to manage that complexity on our behalf. This would not only make life easier for taxpayers, it makes economic sense: the findings from our research suggest that for every extra dollar spent on the ATO, there could be a hundredfold reduction in external costs in running the system. This would free up a great deal of unproductive private sector tax consultants, accountants and book-keepers, giving them the time to do more productive work.

Will this happen? I don’t think so. Just prepare, as a taxpayer, to manage a new type of complexity.

Last month I went to two conferences in Sydney: one on Information Architecture and the other on Plain English.

Undoubtedly, I upset a few people at both by suggesting that some of the projects reported were not of an adequate standard. In the case of the Information Architects I was critical of the stakeholder management processes used in a large website project. In the case of the Plain English conference, I had already lobbed a few grenades before the conference began, arguing that Plain English is an inappropriate basis from which to develop an adequate standard for public communication. Three days of careful listening to presentations substantially confirmed my views, though I now have a better insight into some of the possible reasons for the inadequate standards.

Shooting the messenger is one of the ways in which people deal with adverse criticism, and there were plenty of shots directed personally at me and, more generally, at the vague body of naysayers like me. But I’m an old warrior with thick armor, no stranger to controversy, and I like a good fight. So I didn’t roll over, nor did I retreat into my bunker to lick my wounds. I stand by the criticisms I made, and if need be, I will make them again.

For those of you who are still reading this, let me explain why these criticisms should be taken seriously by Information Architects and Plain English practitioners and advocates.

I’m a communication researcher. It’s my job to investigate routine communication practices such as Information Architecture and Plain English and to create new practices such as diagnostic testing; it’s my job to test them out in the field, find out what works and what fails, and based on my findings, promote the best practices and discourage poor practices. Above all, I offer evidence that can be publicly scrutinised and evaluated by my peers. Most of what I do is in the public domain and is reported on our Institute’s website or in peer reviewed publications.

I am not setting myself up as an authority beyond question, an unchallengeable arbiter of what should or should not be done. Far from it: I make the criteria I use and the evidence they are based on as public and as accessible as I can, and welcome open discussion.

I could, of course, do this work quietly in the back room, but that is not my personal style, nor is it consistent with my job description which is to promote good practices and a general improvement in the quality of communication between large organisations and people. And it is worth pausing for a moment to ask why I regard this work as important. The answer is simple. If we do not communicate at the highest standard, some people die or suffer injury, and many people are unable to exercise their rights.

For example, if people cannot appropriately use their medicines because they cannot read a medicine label or leaflet, they can kill themselves. If an electricity linesman cannot follow procedures for inspecting faults on lines because the written procedures for doing so are difficult to use, the unrepaired faults can lead to fires and many people being killed or injured. If refugees cannot make sense of the regulations applied by governments to establish their status, they will be distressed by a process that is supposed to help them.

A high standard of communication can significantly contribute to avoiding death, injury and hardship.

It is also nice to know that high standards of communication lead to more efficient and profitable organisations; but that is the bonus, the icing on the cake. The bottom line is that a poor standard of public communication is unacceptable for safety and social reasons.

There would be some excuse for poor communication if the know-how for creating a high standard was unavailable, but that is not the case. For some time now, tested methods have been available in the public domain. So when I see work that claims to be ‘professional’ yet falls short of acceptable standards, I voice my concerns.

I could go into a great deal of detail, but two points will suffice. First, professional information designers have known for years that the political management of projects—that is, ensuring that all stakeholders are actively involved—takes up about 50% of the effort in public communication projects; poor stakeholder management is the greatest risk to success of such projects. So hearing the ‘professionals’ at the conferences talking about their recent discovery of political factors, and their accounts of fumbling through the process, caused me great concern. Second, there is an old saying that to a hammer everything looks like a nail. To information architects, it seems, the solution to public communication problems lies in building a website; to Plain English advocates the solution lies in rewriting documents according to their rules. Such rapid moves into the solution to communication problems shows a sad lack of awareness of contemporary design problem-solving methods used in communication and information design.

I suspect that by making these remarks I shall get fewer invitations to speak at conferences, but that does not matter. What matters is that people continue to be needlessly harmed and disadvantaged, and that must be addressed, regardless of who says it.

Raising the standard from what to what?

Having attracted lots of flack from my recent Blog on Plain English (PE), I thought those with an interest in such matters might like to see the presentation I gave at the recent PE Conference in Sydney. It’s an unashamed advert for our new graduate course in Performance-based information design

BTW, I still stand by my criticism of PE, but having sat through three days of PE papers, I have a better idea of why PE is where it is. More on that in a later blog.

It was a well organised conference. Many thanks to Neil James of the Plain Language Foundation for making me feel welcome, despite my criticisms.

The issue in this title is currently preoccupying regulators all over the world. So I am writing this specifically for you: our hard-pressed, under-resourced guardians of the public interest.

Over the last twenty years we at the Communication Research Institute have worked with many government and industry groups to answer this question. We have done so in Europe, the USA, and Latin America as well as New Zealand and Australia. And we have done this work in many product areas: health, finance, insurance, food, agricultural and veterinary products, utilities and so on.

Usually we approach the problems faced by regulators on a case-by-case basis, separately, within each jurisdiction and product group.

But life is short, and we have found that many of the principles for effective regulation of consumer information are common across all areas. So here is a summary based on our research and experience.

1. Forget about content

It may come as surprise to many of you regulators that we advise you against developing the content—the specific wording and layout of regulated information. Within this injunction, we include templates, model documents, and guidelines.

The first reason for this is that you typically don’t have the professional information design skills you would need to do this work: writing, editing, typography and layout for public information. It takes about 4 to 5 years training and a few more years of practical experience to become proficient in these crafts. No amount of two-day workshops in Plain language writing, typography, or information design will give you the necessary proficiency and skills. The best such short-term workshops will do is open up to you some of the problems and issues in these fields. So don’t even try. Your attempts are almost always embarrassingly inept.

(I could give you many examples, but I’d like to help rather than put your backs up.)

The second, and by far the most important reason, is that even if you had these skills, you would be hard-pressed to come up with a model document that works effectively across the range of products over which you have jurisdiction.

Research repeatedly shows that effective information is determined by the context in which the information is used, far more than any other factor. Simple things such as the shape of a particular package, where the folds occur in a document, where the product is used, and the specific characteristics of the product and customer all play a much larger part in determining the effectiveness of the information than the wording and layout. One size can never fit all; it doesn’t even come close.

If you think this sounds like a council of despair, think again.

2. Focus on performance and outcome

Start with a simple question: What do we want people to do with the information that we regulate? The quick answer is usually something like: ‘We want consumers to make informed choices’. This is a high level, wide choice answer, but you need to be much more detailed because a wide choice is usually made up out of a lot of narrower choices.

Here is a practical example from over-the-counter medicine labelling regulations (TGA 69A).. The regulations say:

For non-prescription medicines, the aim is that the information on the label is presented in such a way that consumers can:

choose an appropriate medicine on their own;

use the medicine safely and effectively;

readily find the information they need, understand it and act on it appropriately;

and access further information, if they want to know more about the medicine.

That’s the high level statement in the regulations.

The regulations then refer to a more detailed list of requirements in the industry code of practice:

what should people be able to do with labels
Consumers who say they are able to read English should be able to use the label as stand-alone information, without help, to:

find at least 90% of what they look for on a label

use appropriately at least 90% of what they find.

…..Below is a list of tasks that consumers should be able to perform with any non-prescription product at the point of sale, and later at the point of use.

at the point of sale	at the point of use
identify and select	use	store	dispose of
can locate and read product name can locate and read quantity can identify what the product is used for can identify circumstances under which the product should not be used	can locate, read and understand product description can locate and read product ingredients can locate, read and understand dosage and usage instructions can locate, read and understand any warnings can locate and read information/enquiry number	can locate, read and understand storage instructions	can locate and read expiry date

Most of the stakeholder consultation in formulating these regulations and code of practice took place around the specification of these particular tasks.

We have helped develop similar regulations and industry codes of practice in a wide variety of jurisdictions and product types.

How do the final documents look?

Well, that is up to the industry. This is where all the competitive skills of industry are brought to bear. No two solutions need look the same, as long as industry can satisfy the regulator that the product information is usable in the way required in the regulations.

How do you, the regulator, know that the product information is usable as required?

To satisfy medicine information regulations, industry has to submit proof that it has applied an appropriate professional information design method, and has submitted evidence from testing that the information is as usable as they claim. It is the same as when a pharmaceutical company submits a new product for registration; they have to satisfy you with appropriate data from clinical trials that the medicine will perform as they claim. Medicine information needs a similar requirement.

There are many products like medicines which are unusable without adequate information. Further, there are products like finance and insurance where the products themselves are the information. In all of these, the information for consumers should be of the highest standard.

So instead of writing and layout skills, the extra skills you will need as a regulator are:

1. ability to identify when professional information design services are used
2. ability to appropriately interpret the result of testing submitted to you by industry.

Finally, with this type of regulation, you do not have to unduly restrict competitive behaviour. There is plenty room for innovation and new ways of designing product information to seek competitive advantage. I commend it to you.

Communication is a highly ambiguous activity, dependent on a myriad of contextual factors. In many cultural contexts ambiguity is highly valued. There is something mysterious, magical and perhaps powerful in meanings that defy and resist being pinned down. But in other contexts, ambiguity needs to be minimised. One such context is the providing of information: giving directions, explanations or instructions, sending out bills and forms, describing the legal or financial obligations of a situation, and so on—that is, those contexts where people have to act on information, and where the consequences of inappropriate action could be disastrous.

Designing information so that people can act on it appropriately is not easy. There are so many problems: problems of ambiguity of meanings; problems of how we read and use information, where we look for it, what we expect, and how we react; problems of literacy, choice of words, illustrations, typography, layout, tone…I could go on, but these are enough problems for now.

Approaches to the useful and efficient design of information vary, and at bottom are based on how information designers understand the nature of communication.

One extremely common view is known as the sender-message-receiver (SMR) model. This works as follows. Person S (the sender) wants to communicate something to Person R (the receiver). S knows precisely what he (or of course she) means to say, and clothes this meaning in words (encodes it, to use the jargon) to produce a message, which he then sends to R. R having received this message undresses (decodes) the message to reveal S’s meaning beneath the words. As long as S has chosen the clothes carefully, according to a set of rules, the result is a beautiful symmetry or transparency between sender and receiver (or speaker and listener, writer and reader, information-giver and information-finder, etc).

This idea of communication, as a movement of ideas from one mind into another, is the theory which informs the Plain Language movement. Plain language experts clothe meanings according to the Plain Language rules. The rules are fairly simple: short sentences, everyday vocabulary, no fancy punctuation, and so on. By following the rules, they claim, they can send clear, unambiguous messages. If this seems to you sensible, even commonsense, then you too should become a plain language advocate and learn how to scrub the everyday world of public communication clean, leaving no trace of ambiguity or misunderstanding, just a beautiful transparency of ideas between minds. This is the vision splendid of a world of public discourse given over to plain language.

And, of course, we would expect advocates of such purity to practice what they preach, being a shining beacon, an example to us all.

How odd then and deliciously ironic that a forthcoming international conference on plain language should have an ambiguous title. It’s called ‚’Raising the standard’ and as if to reinforce the ambiguity in the word ‚’standard’, on the website advertising the conference is a picture of a flying flag. How is such ambiguity possible? Does one meaning reinforce the other? If I become an advocate—raising the flag/standard—will I also raise the standard of language use in our midst? Does the one idea necessarily lead to the other? If I believe in something, will it come true? Well, not necessarily.

The irony is doubly revealing. On the one hand it reveals a naiveté, a common weakness in true believers: We believe it, so it’s the Truth.

On the other hand, because faith conquers all, it reveals a disregard of simple rationality. If people claim to be raising the standard of language usage, it’s legitimate to ask what they are raising the standard from, and towards what. How are we to know at the end of the day whether or not the standard of usage has been raised? What is it today, and what do we want it to be tomorrow? On this all-important question plain language advocates are oddly mute.

As the conference is being held in Australia, not the embarrassingly backward USA, it is worth pointing out that the Australian Federal Government has had a Plain English Policy since 1983. Plain English, as a writing style, has now permeated most of the public sector at Federal, State, and Local Government. Further, it is commonly used in businesses that deal directly with the public. Most large banks, insurance companies, retail traders and service providers use the plain English style of writing as the default style in communicating with the public. There are, of course, exceptions, but they are notable for being so. Plain English is the norm.

Do Australians feel that they are living in a society in which clarity and transparency are the norm? I suspect not. Yet with all this plain English about, how can this be so? Could it be that plain English is not as clear as it seems to the true believers? Is there evidence to the contrary, despite the ‘raised’ standard? Well, yes, there is a great deal of evidence to the contrary: not only does the communication model embraced by the Plain language movement defy 400 years thinking in the philosophy of language and 100 years researching in psychology, but also there is a large amount of empirical evidence that shows that on its own, plain language is not a sufficient nor necessary ingredient of clear communication.

At the margins of this great conference, I will be giving a paper on an evidence-based approach to standards in public communication. In it I will suggest, based on evidence from many case histories, that skilled language use (not necessarily plain) plays an important but relatively small part in creating a high standard of public communication, seldom exceeding 10% of the total effort. Other factors and a range of skills, beyond those of writing in a particular style, account for a much larger share of the costs in raising the standard of public communication from its current poor level (as measured) to a measurably higher standard.

The final irony is that if someone who is an expert in Plain English tells you they can create clear and transparent communication, they may be misleading you. They can write in a style that superficially looks clear, but to use a non-plain, non-English adage, caveat emptor.

In October I will be giving two conference papers about the gap between advanced professional information design practice and contemporary Information Architects (IA) and Plain English (PE) advocates.

One paper will be at the Australian IA Conference, the latest in the series of highly successful conferences organised by Eric Scheid.
For information and to register, go to:

http://www.oz-ia.org/2009.

Good news for readers of this blog: you are entitled to a discount. When you register, use the code: DS0258.

The other conference is a PE talkfest of as yet indeterminate quality (apart, of course, from my paper). You can register at:

http://www.plainenglishfoundation.com/Conference/tabid/3270/Default.aspx

Here is a brief summary of the ground I will be covering in these papers.

In the 1960s and ‘70s, some of us in the information design research and practice community were asking ourselves: What methods and research findings will lead to improvements in information designed for people?

By the late 1980s, before the wide-scale use of the internet, we at CRIA published a number of case histories demonstrating these methods and their effectiveness. But because this research was conducted outside the emerging interest in Human-Computer Interaction (HCI) and later the internet, it was largely ignored by the usability communities (though one of our case histories was incorrectly cited by Jakob Neilsen in his Usability Engineering 1994), including many in the IA and PE communities.

In the 1990s, we asked a new question: could we use these methods not just to bring about measurable improvements, but to bring about consistent improvements so that all information of a particular type could be improved to a particular standard?

In 1994 we published the first of a number of guidelines and case histories that clearly showed it was possible to design information to a consistently high standard.

Once again, we saw no evidence of these types of guidelines in IA work and even less so in the PE community.

The next step was to get some of these standards built into regulation so that industry would be required to meet them. We had some unexpected success with the EU in 1998, and with the Australian Government in 2004. Around the same time, we successfully implemented these standards in the Australian and Mexican industry codes of practice and guidelines.

This process of creating information design standards is likely to accelerate, particularly with current government interest in the effectiveness of communication in both the health and financial sectors.

Thus the game has changed and keeps on changing; and the IA and PE communities are still playing catch-up.

The problem faced by both IA and PE advocates is that if they don’t catch up, their current professional performances may fall short of the standards they will be required to meet.

We will shortly offer a number of post graduate training courses to help our IA and PE colleagues catch up. Register on our web site to make sure of your place on these courses.

This is important work and we want to share the know-how. I look forward to IA and PE catching up. And I look forward to seeing you at one or both of these conferences.

Remember to use the code DS0258 when you register for the IA conference.

Local governments’ communication with ratepayers could be done better and more cost effectively.

Local governments provide a more diverse range of services within one organisation than any other arm of government: health, education, social welfare, urban planning, recreation, libraries, engineering, environment, parks, refuse disposal and recycling – the list goes on and keeps growing. Consequently, they face unique communication challenges.

I have had the pleasure of working with many local governments over the last twenty years, and I am constantly in awe of their accomplishments and the diversity of their services. But I have been struck by the uneven quality of their communication with their ratepayers. While there are some well-designed communications, many are not. There are too many rates notices that are hard to make sense of, letters that are difficult to understand, websites that are hard to navigate, brochures that don’t explain what to do, and newsletters that provide no news.

The many examples of poor communication alongside the pockets of good work suggest a lack of coherent and effective communication policies, strategies and practices in local government. We have worked with a number of local governments to rectify this, and the results are impressive; but there is much to do.

When we review communication practices in local government, we look for two types of evidence.

First we look at outcomes. Things such as payment patterns, call centre traffic, counter transactions, turnaround times, and complaints handling provide us with good baseline data on current performance and the costs of dealing with poor communication practices.

Second we examine the processes used to develop and monitor communication with ratepayers. Research on communication and information design has provided us with a good deal of evidence about those communication processes which work, and those which don’t.

We can now look at the methods and stages through which any communication has been developed, and spot the likely problem areas. Here is a list of some of the indicators we use – some of these are obvious, but some may surprise you:

• -absence of craft skills in writing and design
• -no evidence of performance
• -use of ‘seals of approval’ such as crystal marks or clarity marks
• -use of focus group and surveys
• -inadequate scoping
• -no performance requirements
• -no benchmarking
• -poor implementation
• -no monitoring.

These are the most common symptoms of a lack of effective communication policies and strategies guiding practice and the presence of poor communication processes and practices. The result is an organisation that is spending too much for unmeasured and probably inadequate outcomes.

Websites have exacerbated these problems in recent times. A simple rule of thumb can be applied. If an organisation started out with a poorly-designed paper system, putting it online makes it worse. Far from improving access to information and services, websites have added an extra burden of complexity and frustration resulting in an overloading of compensatory services such as call centres.

Those of you who are cri members can use our free diagnostic kit, our many case histories, and our services to help you work though what you need to do to improve your communication design processes.

For those of you who are not, joining us might be a good idea.

As part of our ongoing research, we monitor the usability of many websites. Some of these are the websites of CRI corporate members, others are large-scale corporate websites which many people use and depend on.

We are observing a disturbing trend. The usability of many of the sites we monitor is going backwards. Some sites were not very good to start with. But in a number of cases, after major redesigns, their usability has got worse.

Some of the obvious symptoms of this deteriorating usability are:

• -unnecessary use of photographs and flash
• -too many menus and navigational devices
• -poor typographic hierarchy
• -indiscriminate use of lines, boxes, icons and colour.

These are, of course, just the outward symptoms. The consequences are sites that are unnecessarily difficult for people to navigate and use.

Typically, organisations do not know a great deal about the usability of their sites before they go through an expensive redesign, so they are in no position to make a judgement about their website’s usability after the redesign. As a consequence, they cannot tell whether they have got a decent return on their investment (ROI) in the redesign.

Based on our experience with the current generation of websites, we would suggest that an organisation should expect a minimum $10.00 ROI in productivity improvements for every $1 spent on a redesign. If you are a commercial organisation, selling directly to the public, an ROI of $100 for every dollars invested is not an unreasonable expectation.

These large ROIs say something about the poor quality of many current generation websites and how much they could be improved. In some cases, the only reason the websites work at all is because of the ingenuity and perseverance of the people who use them, rather than the skill of the designers who create them.

And judging by some of the recent redesigns we are seeing, web designers are not getting any better at their craft.

keep looking »

© CRI 2009 David Sless’s soap box