Just saying “Nudges are not enough”…is not enough! The Lords and Behaviour Change

The House of Lords Science and Technology Committee has this week published its report on Behaviour Change. A video of the Chair of the Committee talking about the report is also available.  TCC was pleased to have been able to make a submission, which is listed on page 79. The report is important as it sets out the clear purpose for this sort of Government activity:

The aim of much government policy is to bring about changes in people’s behaviour and so a government’s success will often depend on their ability to implement effective behaviour change interventions whilst, at the same time, avoiding significant harmful side effects.

Governments can use a variety of different types of policy interventions to change the behaviour of the population. These range from providing information or undertaking campaigns of persuasion that promote certain behaviour, to taxation and legislation.

News coverage of the report in the Guardian and the BBC focused on their broad point in the report that behavioural Nudges are not enough:

The currently influential book Nudge by Richard Thaler and Cass Sunstein advocates a range of non-regulatory interventions that seek to influence behaviour by altering the context or environment in which people choose, and seek to influence behaviour in ways which people often do not notice. This approach differs from more traditional government attempts to change behaviour, which have either used regulatory interventions or relied on overt persuasion. The current Government have taken a considerable interest in the use of “nudge interventions”. Consequently, one aim of this inquiry was to assess the evidence-base for the effectiveness of “nudges”. However, we also examined evidence for the effectiveness of other types of policy intervention, regulatory and non-regulatory, and asked whether the Government make good use of the full range of available evidence when seeking to change behaviour.

Is this a great surprise nowadays? The Nudge blog itself recognises that the definition of Nudges made by the Lords is not a magic bullet and says:

To an applied behavioral scientist, nudging is part of a broader application of behavioral science principles, which can be understood as an engagement with how a boundedly rational decision maker with a heterogeneous set of material and non-material preferences interacts with the world around them.

TCC have also made the same point in this blog: here and also here.

If it is accepted that Nudges need to be seen in context, then what other elements need to be addressed? The Lords clearly recognised there was a need for a lot more population-level research in order to test what worked and develop practical approaches that can more easily translate into deliverable interventions:

We heard evidence that, although much was understood about human behaviour from basic research, there was relatively little evidence about how this understanding could be applied in practice to change the behaviour of populations (“applied research at a population level”). We make some recommendations to address this issue.

Although we acknowledge that further applied research at a population level is needed, we also found that the available evidence supports a number of conclusions. Our central finding is that non-regulatory measures used in isolation, including “nudges”, are less likely to be effective. Effective policies often use a range of interventions.

We concluded that it is important to consider the whole range of possible interventions when policy interventions are designed. We place particular emphasis on this conclusion because the evidence we received indicated that the Government’s preference for non-regulatory interventions has encouraged officials to exclude consideration of regulatory measures when thinking about behaviour change. Though there is a lack of applied research on changing behaviour at a population level, there is other available evidence that the Government need to use to better effect. We were therefore disappointed to find that, although we received some examples of evidence-based policies, such as policies on energy-efficient products and smoking cessation services, we were also given many examples of policies that had not taken account of available evidence, including policies on food labelling and alcohol pricing.

The Lords were also good at recognising much more work needed to be done around effective evaluations, better measurement of outcomes and better co-ordination across government:

We also found that a lot more could, and should, be done to improve the evaluation of interventions. This is not only good practice but would help to build a body of research that could inform effective policies targeting population-level behaviour change.

Understanding behaviour and behaviour change are necessary for developing effective and efficient policies in all areas. Although this report draws on case studies that focus on the Department of Health and the Department for Transport, our conclusions and recommendations are directed to all Government departments.

However it was surprising how little they covered issues such as Social Marketing, which has a long pedigree and larger evidence base. Social Marketing has always recognised the mix of “operational” or “downstream” (non-regulatory) and “strategic” or “upstream” (regulatory) approaches to an effective behavioural intervention. It therefore looks as if the Committee were quite narrowly focusing on the political position of the Coalition Government over lighter regulation towards behavioural intervention rather than addressing behaviour change as a whole.

In addition the report did not consider in more detail issues such as developing learning around an effective mix of segmentation approaches. TCC has done a lot of work in the field of segmentation that goes beyond traditional geodemographics which covers the how and what of behaviour to also look at the why in terms of needs, motivations and values that drive it.

Thus perhaps the first thing we  should do is move away from the simple “Nudges are not enough” framing of the debate and look at what additional approaches are additionally required to deliver effective behavioural intervention.

Charlie Mansell is Research and Development Officer for The Campaign Company. If you want to see what your own primary values set is, why not take the simple Values Questionnaire here.