When I talk about plain language in India, some of the questions I am asked are: Who practises it in India? Do Indians really care about plain language? This line of questioning seems to assume that plain language is a niche cause and isn’t of much relevance to most people.
Today I have some evidence to show that plain language is indeed practised in India, and no less by ICICI Bank, one of the top private sector banks. But there’s a catch. We’ll come to that.
Take a look at the Bank’s terms and conditions for Indian users. You’ll find:
- The very familiar legalese such as repugnant, thereof, and more;
- Lots of nominalizations such as “by giving a written notice”, “during which any maintenance work or repair is required to be carried out”, “Customers can make financial transactions”;
- Even gendered pronouns (from which century is this text?!);
- No proofreading: “external service provider,s or agent's”.
No surprises here.
The readability statistics of this document as measured by Microsoft Word:
Words per sentence: 37.2
Flesch-Kincaid Grade Level: 19.6
Now take a look at the Bank’s privacy notice for EU users. The familiar legalese is missing and you do a double take: Is this the same company?
“We” and “you” are used plentifully. So are tables and vertical lists, though the numbering is a bit off in places. Note how these are missing from the India terms.
Of course, it could be plainer.
Example 1:
Original:
“We are permitted to process your personal data in compliance with Data Protection Legislation by relying on one or more of the following lawful grounds”
Plain language rewrite:
“The Data Protection Legislation permits us to process your personal data on these grounds”
Example 2:
Original:
The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
- to provide services to you;
- to ensure that our customer accounts are well-managed;
- to prevent, detect, investigate and prosecute…
Plain language rewrite:
The processing is necessary to:
- provide services to you;
- ensure that your account is well-managed;
- to prevent, detect, investigate and prosecute…
The document could be clearer in more ways. But the point is that it is head and shoulders above the terms document for India.
Its readability statistics as measured by Microsoft Word:
Words per sentence: 23.9
Flesch-Kincaid Grade Level: 14
Passive sentences: 18.4%
Do note that I have used the readability statistics simply to provide a broad comparison between the two documents. Readability tools cannot accurately assess clarity.
Obviously, ICICI Bank can do a fairly good job of writing clearly when they put their mind to it. I’m guessing this is true of other Indian corporates as well.
So then why are Indian customers crammed with gobbledygook, while EU customers get clearer communication?
The answer is: regulation. Sometimes from within and sometimes without.
Led by central banks, many banks and financial organizations in Europe have consciously chosen plain language to bring about transparency, trust, and better customer experiences.
And this has not come about in a vacuum. Europe has had a long history of plain language, with many countries requiring it by law. In particular, regulations in the banking and finance sector require clarity, the latest among them being the EU Accessibility Directive. In the UK, the Financial Conduct Authority practises plain language and expects companies to follow suit.
In such a setting, ICICI Bank would rather not stick out with its thereofs and repugnants. I am not surprised. A few years ago when I came to know about the booming job scene for plain language summary writers in India, I was told that they were all writing for clients abroad.
To sum up, the question is not whether Indians care for plain language. It seems we are simply waiting for plain language to become a compliance requirement. That too may not be far, given the many developments that are afoot. But if you keep waiting for too long, you may have a tough time playing catch-up.
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