There is yet another new Nudging tool on the market: FORGOOD. Is this the be-all end-all model we were looking for?!
FORGOOD was developed by Leonard Lades and Liam Delaney to move the philosophical debate on nudging, with a strong focus on the ethical side, into the actual tool. As such it can be argued that FORGOOD is not as much a tool, as an ethics framework. To quote: "FORGOOD is a framework that synthesizes the debate on the ethics of nudging in a memorable mnemonic. It suggests that nudgers should consider seven core ethical dimensions." So, what does it stand for? What are these seven dimensions? FORGOOD is an acronym for Fairness, Openness, Respect, Goals, Opinions, Options and Delegation. To grasp the full complexities of this tool, we will discuss each of these in turn:
Table taken from Paper Fairness Fairness is a tricky term, regardless of the field you're in. The definition of fairness within FORGOOD focuses on how nudges affect different people differently and how these asymmetric effects often arise from design. And not all effects are positive either. It is possible that a nudge, although beneficial to some, is detrimental to others. Fairness then becomes a question of: is there an effect of redistribution going on? And is benefitting one group worth the possible negative spill-over effects another group? The authors suggest that udge practitioners should consider whether the policy changes welfare on balance, and suggest measuring the redistributive effects of nudges. One way of measuring this is by identifying pre-nudge and post-nudge dispersions in key variables. Other options are to identify the change in the distribution of key variables and/or by identifying and comparing first-order effects on the targeted behaviours and second-order effects on other, not-targeted behaviours and outcomes. It has to be mentioned that FORGOOD doesn't give very strong guidelines on this. The authors state that whether or not redistributive effects of behavioural interventions are undesired will depend on many context variables and as such is up to the discretion of the practitioners involved. Openness Knowing what we know about behavioural change, some nudges stand or fall by how open they are. Openness meaning whether they are overt or covert. A lot of traditional policies are highly visible, think of taxations and bans. As such, they can easily be scrutinized and assessed by the public. This is a valuable characteristic because transparency prevents manipulation and manipulation is often viewed as ethically problematic. However, most of nudging is kind of based on manipulation, whether people like to call it this or not. The authors argue that a policy's openness can be defined in at least two ways. It is open if it is (1) communicated openly and (2) easily acknowledged by perceptive consumers. But the authors also argue that they don't think adhering to only the first definition is enough. They argue that individuals whose behaviours are influenced should be aware of the policy and satisfied with it. Hence, another definition of openness is that it should be possible, in principle, for everyone who is watchful to identify the influence of the policy on behaviour. The idea of openness here alludes to the fact that rather than knowing that something works, the idea should be that aware consumers can understand its effects and that both them and practitioners can understand why the nudge is working. Respect
To be ethically acceptable, behavioural policies need to respect people and in particular their autonomy, their dignity, their freedom of choice and their privacy. The authors argue that this is especially important when discussing Type 1 nudges, which tend to work via the automatic decision-making System 1. In simple language, this means that people should not be treated like ignorant children who are unable to make decisions, let alone good decisions. Moreover, another important aspect of respect means that nudges should not stigmatize those being confronted with the nudge, and actively choose to not adhere by it. An example given of this by the authors refers to when pictures of obese people are presented on the packaging of unhealthy food products. Respect here refers to adhering to the freedom of autonomy and of choice people should have. Also very important with regards to respect, especially as Big Data is making waves is to respect people's right for privacy and control over the use of their personal data. Policies that respect privacy give people the opportunity to give or withhold their consent for different uses of their data.
Goals
An important characteristic of nudging, or any policy really, is whether they serve good goals. But what does good mean? Well, the goals of nudges that are in the spirit of libertarian paternalism are to make people's lives ‘better off, as judged by themselves’ according to Sunstein and Thaler who came up with the whole concept. Under this ‘better off, as judged by themselves’ criterion, nudges change people's behaviour in a way that these people approve of and are thus ethically legitimate. So no, you don't make the cut for the FORGOOD framework if your nudge benefits you, or the group you belong to, at the detriment of others. That's not a good goal, nor is it very fair... Other goal-related issues you might run into is that the nudge has a good goal (good for the environment, the country as a whole etc.), but is not judged as such by the individual. No one wants to be inconvenienced by having their food choice restricted (eating less meat) for example. The authors identify this as a potential issue, but do not draw a hardline on its acceptability for FORGOOD. They simply state that all the ethical issues, and their context has to be considered. Opinions Once a nudge is open, people will be able to comment on it and share their opinion. And unsurprisingly, there is a wealth of difference in what people do, or do not find ethically acceptable nudges. When dealing with a lot of people to be nudged, it is almost inevitable to find someone who strongly disagrees with either the goal or the method (or both) of the nudge. It might not even be possible to design a nudge that everybody accepts as permissible. It is important to know, as a practitioner, how much disagreement is bearable and measure the extent of agreement/disagreement. A very important aspect of this disagreement is to determine what value should be given to the views of dissenting minorities? When it comes to finding out public opinion, things get a little easier: you can just ask people whether they think something is acceptable, yay or nay.
Options
It is also good to keep in mind that nudging itself is not the be-all-end-all of methods. We do have other ways to induce or reduce certain behaviours. If nudging isn't the way to go, there are always harder policies to implement, such as bans or incentives.
We have to keep in mind that nudging as a policy option is rather young, and the empirical evidence supporting its effectiveness, but also its cost-effectiveness is not yet full grown. Moreover, cost-effectiveness is not always the highest good to aim for. Some policy makers argue that although nudging can be very cost-effective, in comparison to harder policies it's less effective, all things considered.
Delegation
Considering delegation as an ethical aspect moves away from the nudge itself, and looks deeper into the power balance that inevitably comes with nudging: who is the nudger, who is nudgee, and what does this relationship entail? The most important question might be: how was the power to nudge delegated to them?
The most obvious thing to look at are possible conflicts of interest. Conflicts of interest c;an trickle into other aspects of the FORGOOD framework as well; they might influence public acceptability and constrain the set of other policy options.
It is important to show that practitioners and their respective agencies have reflected on potential conflicts of interests, and that they can make an effort to communicate why they are (or why they think they are) legitimated to influence people's behaviours.
Another aspect is competency. Is the nudger competent enough to be the one influencing others? Policy-makers are humans too, and are also subject to cognitive biases, maybe even the very ones they are trying to change. The design and evaluation of different types of nudging initiatives may require expertise outside the capacity of the institution, and it merits discussion as to how risks in this regard are dealt with. Personally, I think a lot of these issues can be fixed by having extremely diverse ThinkTanks, or focus group meetings in which all stakeholders are properly represented. But that's just me.
So, there you have it: nudging FORGOOD. It's not exactly the only nudging tool on the market, but it differentiates itself well enough, by including a more philosophical approach towards something that the average liberatarian has no desire to discuss: ethics. Now I'm curious to hear what you think: Is FORGOOD just another tool to create some hype, or do you think it's actually worth your time?!
References: Lades, L., & Delaney, L. (n.d.). Nudge FORGOOD. Behavioural Public Policy, 1-20. doi:10.1017/bpp.2019.53
