The readability of the millions of privacy notices now hitting mailboxes to comply with a provision in Gramm-Leach-Bliley Act are difficult to read for the average consumer, according to a newly released study.
The study reviewed 17 privacy notices from a variety of financial institutions that have until July 1 to notify customers of their privacy policies and offer those customers the opportunity to opt out of sharing personal information with third party marketers.
The notices reviewed were found to average a third-to-fourth year college reading level, making them difficult to read. Because of a gap between education level and reading level, literacy experts recommend that materials written for the “general pubic” be at about a junior high school reading level, according the to the study’s author Mark Hochhauser, a readability consultant based in Golden Valley, MN.
“Consumers will have a hard time reading and understanding the privacy notices they receive from their banks,” Hochhauser said in the report. “The notices were supposed to be written in a “clear and conspicuous” style so they would be “reasonably understandable.” Instead, the notices I reviewed were poorly written with too many long sentences and too many uncommon words.”
In other findings, the notices averaged 25 words per sentence, 10 words over the ease of readability recommendations of 15 to 20 words per sentence. The notices averaged about 46 sentences per notice, with only 13% of the sentences estimated as “short”. Three notices were classified as having “weak” writing style and 14 had “poor.”
Notices rated “very difficult” in reading ease included notices from Chase, American Express, California Federal Bank and Countrywide Loans. American Express scored the highest number of words per sentence, 32, among the 17 notices. Anchor Bank, while rating “difficult” in reading ease, scored the lowest number of words per sentence at 18. Others that rated “difficult” included Discover Card, Bank of America, Capitol One, USbancorp and Macy’s.
The report also said that many states have readability requirements for insurance polices sold within the state. For example, Arkansas, Indiana, Kentucky and Ohio require a minimum score of 40 on the Flesch Reading Ease. Only four of the 17 notices reviewed met that requirement. Among states that have tougher standards, such as Connecticut and Florida, which require a minimum of 45, none of the notices would have met those requirements.
“If consumers are unable to easily see, read and understand these privacy notices, how can they make informed decisions regarding a bank’s use of their personal information,” Hochhauser said.
The 17 notices were reviewed using several software programs including Prose, Wstyle 1.6, Grammatik 6, Reader 1.2 and Correct Grammar 3.0. The programs calculated the Flesch Reading Ease Score, passive voice sentences, words per sentence and word commonness.
