Critical Information Summary documents are now compulsory and we’ve lost track of the number of them we’ve been asked to review over the last 48 hours, but amid the blur one thing is very clear: It’s better to keep CIS statements short and sweet. It’s not meant to be a small print version of your Standard Form of Agreement, or an extended and glowing reference for your business and its entire product range.
It’s meant to be a short, clear summary of really important points about a particular product. It’s not a General Information Statement, or a Product Disclosure Booklet. It’s a Critical Information Summary. Two of the three words in its title emphasise that it’s to be pithy and highly concentrated.
How simple?
Well, as simple and brief as it can be while addressing the disclosure requirements of the TCP Code. There’s no harm in adding a bit of ‘wrapping’ but we’ve seen a few CISs where it was hard to find the essential bits.
What’s wrong with complexity?
For the consumer, it defeats the purpose of having a CIS in the first place. If information is buried in long paragraphs, it will be impossible to use CISs to conveniently compare different products.
For the telco, it makes the CIS hard to write, hard to update and hard to audit against the TCP Code’s actual requirements.
Verbosity is a soft option
An insightful wit once finished a letter “I am sorry this has been such a long letter. I didn’t have time to write a shorter one.” And former US President Woodrow Wilson, asked how long he spent preparing his speeches, replied:
It depends. If I am to speak ten minutes, I need a week for preparation; if fifteen minutes, three days; if half an hour, two days; if an hour, I am ready now.
The point they were both making is that it is easy to rabbit on, and hard to keep to the point and be concise. Something inside people makes them want to keep adding a few words here and a phrase there and a sentence extra.
In a CIS, if some piece of information or some wording isn’t required by the Telecommunications Consumer Protections Code, or you don’t have another very good reason for including it, throw it out.
