This document outlines five principles for ethical experimentation and nudging in government: 1) Experimentation is used only to promote people's welfare based on evidence. 2) Initiatives rely on the best available evidence. 3) Initiatives are made as transparent as possible. 4) Effectiveness is rigorously evaluated. 5) A careful risk-benefit analysis ensures potential benefits outweigh risks. The document defines experimentation, nudging, and their relationship. It argues not experimenting can be unethical if impacts are not measured. The principles are meant to complement ethics guidelines and were informed by research on nudging ethics.

1. Five Principles for Ethical
Experimentation and Nudging in
Government
Developed by the Behavioural Insights Research and Design (B.I.R.D.) Team at
ESDC’s Innovation Lab, and partners (TBD)
To provide feedback contact emilie.e.gravel@hrsdc-rhdcc.gc.ca or rebecca.friesdorf@hrsdc-rhdcc.gc.ca

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TABLE OF CONTENTS
What is experimentation?........................................................................................................... 3
What is nudging?........................................................................................................................ 3
What is the relationship between nudging and experimentation?.............................................. 4
Why NOT engaging in experimentation may actually be unethical………………………….. 4
Five Ethics Principles for Ethical Experimentation and Nudging……………………………. 6
Using experimentation only when it is consistent with and actively intended to
promote people’s welfare……………………………………………………………...
6
Experimentation initiatives will rely on the best available current evidence about the
subject matter………………………………………………………………………….
6
Experimentation initiatives as transparent as possible………………………………... 7
Rigorously evaluate the effectiveness of experimentation……………………............. 7
An Example Case……………………………………………………………... 8
Careful risk-benefit analysis to ensure that potential benefits of experimentation
outweigh potential risks……………………………………………………………….
8
Common Ethical Concerns with Nudging and Experimentation Q & A……………………... 10

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In this document, we present five ethics principles that we have developed specifically for and
are committed to following when conducting experimentation and nudging work. It is meant to
complement our “Practical Guide for Research Ethics in Government”, which outlines the core
ethics principles that must be followed when conducting research with human participants.
We begin by providing definitions for experimentation and nudging, to clarify any ambiguities
related to these terms, and to give context for the development of our principles.
What is experimentation?
Experimentation has been broadly defined by the Government of Canada as “testing new
approaches to learn what works and what does not work using a rigorous method”1 and “the
process by which the validity or efficacy of policies is tested through appropriate research
design”2. The prototypical example of a rigorous method is the randomized controlled trial
(RCT; also called A/B testing), which allows for the direct comparison of different approaches
(i.e., interventions) to determine which one is the most effective. For example, you might
compare three different “job search” tools or “back to work” programs and measure which one
results in the fastest returns to work.
Importantly, innovation, or trying new approaches, is not the same as experimentation unless
rigorous methods and impact measurement are also conducted.
What is a nudging?3
Because humans have cognitive limitations, biases, and habits that sometimes lead to suboptimal
decision making patterns, we can use insights (generated by fields like psychology, behavioural
economics, and cognitive science) about these systematic limitations, biases, and habits, to
“nudge” individuals toward the better options in the decision context. This can be achieved by
altering the “choice architecture” surrounding the behavior or decision, i.e., the physical, social,
and psychological aspects of the context that influence our choices, in ways that promote a more
preferred behaviour rather than obstruct it.
In other words, nudges are interventions that steer people in particular directions while allowing
them to choose their own way. Some examples of nudging include, sending a reminder or
warning, or receiving directions from a GPS; this steers a person in a particular direction, though
the person retains the freedom to ignore such nudges. The use of particular defaults rules such as
opt-ins or opt-outs are a common nudging technique for social programs. It favors one option,
although people can choose the alternative without penalty. Subsidies, taxes, fines, and jail
sentences are not nudges because they restrict freedom of choice ̶ choosing any option other than
the option preferred by the choice architect (the agent who created the options in the decision
context) results in a penalty.
Importantly, because every environment has an existing choice architecture that influences our
decisions and behaviour, nudging cannot be avoided. That is, the default way that
options/choices are presented is a nudge in and of itself. Nudges are a common feature of
1 https://www.canada.ca/en/innovation-hub/services/reports-resources/experimentation-direction-deputy-heads.html
2 ESDC Experimentation Strategy Implementation Plan, 2018-19
3 Thaler, R.H, & Sunstein, C.R. (2008) Nudge: Improving Decisions about Health, Wealth, and Happiness. New
Haven, CT: Yale University Press.

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everyday life, it is difficult to object to nudging in general, and one can only object to
particular nudges.
What is the relationship between nudging and experimentation?
The two major components of experimentation are 1) trying a new approach, and 2) rigorous
research design and impact measurement. At this point in time, nudging is generally considered a
new approach, and when the effectiveness/impact of a nudge is tested using rigorous research
design and measurement we would say that nudging falls under the umbrella of
experimentation. Because nudging must, by definition, preserve freedom of choice it is
narrower in scope than other types of experimentation which may include approaches
(/interventions) to change decision-making or behaviour that are more restrictive or heavy-
handed in nature.
As an example, nudging to increase healthier food choices in a cafeteria might involve the
strategic placement of available choices, such as placing healthier foods at eye level and less
healthy foods above/below eye level (but still in view and available for choosing). Other
approaches to increasing healthier food choices that are not nudges might be making unhealthy
foods more expensive or removing unhealthy food choices altogether. To be able to label these
interventions (be it the nudge or one of the other approaches) experimentation, we would need to
use rigorous methods to test their effectiveness. For example, we could measure the number of
healthy food choices at cafeterias that are strategically placed (at eye level) and compare this to
cafeterias that do not use strategic placement (have more unhealthy foods at eye level), provided
that the cafeterias will be otherwise comparable. Importantly, as can be seen in this example,
nudging may be perceived as the lower risk option because it doesn’t constrain the existing
options available to individuals, preserving the full autonomy of the decision-maker. The other
approaches carry the cost of removing or constraining people’s freedom of choice and are thus
higher risk: if they fail to produce the desired positive result then people may have been harmed
by constraint without justified benefit.
Why NOT engaging in experimentation may actually be unethical
As discussed, experimentation has two core components, 1) trying new approaches, and 2) robust
testing and rigorous measurement to find out if the new approaches were successful. The biggest
reason why failing to experiment can be unethical has to do with the second component: failure
to rigorously measure the impact of initiatives, be they standard (current programs, services, or
policy) or new (changes to programs, services, or policy). Without this second component we do
not actually know whether and to what extent an initiative is effective. Although we (at the
government of Canada) were sometimes limited by systems and data capability restrictions in the
past, which made it it difficult to quantitatively measure the impact of programs, these barriers
are no longer the hurdles they used to be. We thus have a clear responsibility to rigorously test
and measure policy and program outcomes.
With experimentation, there is always a risk that a new intervention may prove to be ineffective
or result in negative unanticipated consequences (which is also the case if we make changes
without measuring impact, but then we won’t know if the result was negative). That said, it is
critical to keep in mind that the fundamental purpose of experimentation in government is to test
interventions for effectiveness at a small scale before large scale funding decisions are made and
implemented to the whole population. In this sense, experimentation is a necessary safety
measure that can prevent large losses in public funds and adverse outcomes for a target
population. Thus, an important change in attitude is required to fully benefit from

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experimentation in government: we must not treat negative or null results as failures and instead
appropriately value knowledge of what is not effective just as much as knowledge of what is
effective, for informing future policy, program, and service design.
In regard to nudging specifically, most nudges are designed specifically to enable people to
devote their limited time and attention to their most important concerns. Given people’s inherent
information processing limitations and potential negative impacts of information overload on
well-being (e.g., information overload syndrome4), integrating nudging in service and program
design is an important testimony to the Government of Canada’s commitment to the delivery of
high-quality services and well-being of Canadians.
4 Afari, N., & Buchwald, D. (2003). Chronic fatigue syndrome: A review. American Journal of Psychiatry, 160(2),
221-236.

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Five Ethics Principles for Ethical Experimentation and Nudging
The development of these principles was facilitated by many sources, including the Tri-Council Policy Statement: Ethical Conduct for
Research Involving Humans (TCPS-2)5, Ethical Considerations for Nudging by Cass Sunstein6, Policy Horizons’ Ethics of Applying
Behavioural Sciences to Policy7, and The Behavioral Scientist’s Ethics Checklist8.
Note that these principles are not meant to supplace, and should be used in conjunction with, a human research ethics code (see Doing the
Right Thing: A Practical Guide for Research Ethics in Government) and evaluation, legal and privacy codes of conduct.
1. We will use experimentation only when it is consistent with and actively intended to promote people’s welfare.
a. When we say “promote people’s welfare” we broadly mean aiming to increase people’s well-being (or reduce harm/suffering).
i. Because definitions of well-being can be contentious (i.e., some people think X is harmful whereas others do not), we
aim only to experiment with outcomes that can be clearly linked to scientifically validated indicators of well-being
(e.g., we know that living below a certain income threshold has negative consequences for physical and psychological
health).
b. We experiment only if we think that a new, different way of doing things that has a high potential of improving people’s well-
being.
2. Our experimentation initiatives will rely on the best available current evidence about the subject matter.
a. To ensure that experimentation has the greatest possible likelihood of leading to a positive outcome, we will ensure that the
new approaches we try are based on the most current state of knowledge and best evidence available.
i. A thorough review of the relevant available evidence on the problem under investigation, such as academic literature,
evaluation results, policy or operational insights, and raw existing data will be conducted.
ii. Knowledge gained from the review process will be thoughtfully used to design the new approach.
5 http://www.pre.ethics.gc.ca/eng/education/tutorial-didacticiel/
6 Sunstein, C. R. (2015). Nudging and Choice Architecture: Ethical Considerations (SSRN Scholarly Paper No. ID 2551264). Rochester,NY: Social Science Research
Network.
Cass Sunstein,The Ethicsof Nudging,32 Yale J. on Reg. (2015).
7 http://www.horizons.gc.ca/en/content/behavioural-insight-brief-ethics-applying-behavioural-sciences-policy
8 http://behavioralscientist.org/behavioral-scientists-ethics-checklist/

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3. We will make our experimentation initiatives as transparent as possible.
a. In line with the Government of Canada’s commitment to open government (i.e., open data, open information, and open
dialogue)9, experimentation initiatives will be communicated clearly and openly within and outside of government (i.e., to the
public) as much as possible.
i. This includes the goals, intentions, and justification for experimentation initiatives, as well as their results and
implications.
b. The level and type of transparency should be appropriate for the type of experimentation.
i. Minor interventions, such as simplifying forms, changing the wording or emphasis in a letter, or changing the layout of
a website, require a different level of transparency than changing the eligibility requirements and benefit amounts
associated with a program. For example, it would be too resource intensive to inform Canadians every time small
changes are tested (e.g., mailing 100,000 people to inform them that we will be changing the framing of a few
sentences in a letter, adding clarifying information to online forms).
ii. For major interventions, we will be as transparent as possible by communicating about the initiative prior to its
implementation (e.g., post on a GoC website, use of consent forms for participants), throughout the process (e.g.,
answering questions that arise), and afterward (e.g., making the results and implications available internally and to the
public)
c. In the case of certain study designs, such randomized controlled trials, where people receive different versions of the new
approach, it may not be possible to be fully transparent prior to implementation of the trial. That is, although it is possible to
give general information about the trial, it may not be possible to inform participants about which version of the intervention
they will receive and what the other interventions in the trial are, as this would lead them to react differently to the intervention
than they would naturally, biasing the results. In these cases thorough debriefing immediately after the trial is crucial. For more
information on the ethics of partial disclosure and deception in Doing the Right Thing: A Practical Guide for Research Ethics
in Government and the TCPS-2 recommendations on the subject at http://www.pre.ethics.gc.ca/eng/policy-
politique/initiatives/tcps2-eptc2/chapter3-chapitre3/#toc03-1b .
4. We will rigorously evaluate the effectiveness of experimentation.
a. To understand whether the new approaches we try are effective, we will conduct robust research design, data collection,
statistical analyses, and interpretation of results.
i. Regardless of the potential of a new intervention, how favourably it is viewed by upper management, how well it
worked in other contexts, or how many positive testimonials it received, if we do not rigorously measure its
9 https://www.canada.ca/en/employment-social-development/corporate/transparency.html

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effectiveness in the current context, we cannot be sure that it has a positive effect (for a cautionary tale see Box 1.0 on
“Scared Straight” programs).
Box 1.0
Why we must rigorously evaluate the effectiveness of new approaches
An Example Case: Scared Straight and Other Juvenile Awareness Programs for Preventing Juvenile Delinquency
“Scared Straight” programs were designed to deter juvenile participants from future criminal offenses. Program participants visited and interacted with
adult inmates, and observed prison life first-hand. The idea was that juveniles who see how horrible prison really is will be deterred from breaking the law
in the future. These programs were routinely implemented, most frequently in the United States, over the span of at least 30 years, beginning in the 1970s
and as late at the early 2000s, with the occasional program still operating today. Initially, little systematic, rigorous research on their effectiveness was
conducted. In 2002, a large high-quality meta-analysis of the program was published10
. This review found that “Scared Straight” interventions were not
only ineffective, but “are likely to have a harmful effect and increase delinquency relative to doing nothing at all to the same youths”. The findings clearly
illustrate the importance of robust testing to understand the impact of well-intentioned new approaches/interventions before rolling them out at a large
scale, and the risks associated with failing to do so.
5. We will engage in careful risk-benefit analysis to ensure that potential benefits of experimentation outweigh potential risks11
(see also Potential Benefits and Risks” in )
a. In some cases, the risk of experimentation will be clearly minimal because harm is unlikely. For example, nudging may
involve simplifying forms (reducing jargon, increasing readability), emphasizing important information while keeping the total
information content constant, or adding motivational messaging or step-by-step guides to help people achieve their goals. In
these cases, where the level of risk is clearly no greater than what people would encounter in their everyday lives, we can often
be assured that any potential benefits will outweigh the minimal risks.
i. Regardless, it can be beneficial to consult with a third party independent of the initiative, with research ethics training,
to get a second opinion about any potential overlooked risks.
b. In other cases, new approaches that promise great benefit may come with greater risk and require in depth risk-benefit
assessment. For example, new approaches that require individuals to engage in activities or be exposed to products/events that
they do not encounter regularly in everyday life or were accustomed to previously (e.g., medications, psychological therapies,
10 Petrosino, A., Turpin-Petrosino, C., Hollis-Peel, M. E., & Lavenberg, J. G. (2013). 'Scared Straight' and otherjuvenile awareness programs for preventing juvenile
delinquency. Cochrane Database of Systematic Reviews.
11 For more details, see the section on potential benefits and risks of research in Doing the Right Thing: A Practical Guide for Research Ethics in Government and the
TCPS-2 recommendations on the subject at http://www.pre.ethics.gc.ca/eng/policy-politique/initiatives/tcps2-eptc2/chapter2-chapitre2/#toc02-1b

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financial products, new technologies) would require careful analysis prior to experimentation to ensure that these costs (e.g.,
burdens on time, cognitive resources) are likely to be outweighed by the benefits people will receive in return.
i. If there appears to be real risk of harm or perceived harm, we will consult with an independent, third-party consultant
that is an expert on research ethics to produce a formal risk-benefit analysis.

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Common Ethical Concerns with Nudging and Experimentation Q & A
Question 1: Doesn’t nudging involve manipulating people’s preferences and decisions, often
without their knowledge or consent, which robs them of freedom of choice?
Answer: Although nudging can operate through subtle influences below conscious awareness,
a) freedom of choice is preserved because nudging doesn’t change or hide the choices
available to individuals,
b) nudging is not so powerful that people will be unaware of or unable to consider the
available choices,
c) any choice context (i.e., existing choice architecture), regardless of whether a nudge has
been applied or not, has some influence on people’s preferences, consciously adding a
nudge simply aims to alter the choice architecture so that the option believed to be most
consistent with people’s well-being is more salient, easily processed, or appears more
attractive, without any deception about the objective benefits/drawbacks of any of the
options
Question 2: Experimentation often involves comparing the effectiveness of a new approach with
the effectiveness of the status quo. This comparison often involves random assignment of
individuals to receive either the new approach or the status quo. People sometimes ask, isn’t this
is unethical because it means that some people are receiving better treatment than others?
Answer: This concern often arises from the assumption that the new approach MUST be
superior to the current approach, although we cannot be sure of this until we have directly
compared the two approaches. Second, it is often very important to rigorously measure to what
extent one approach is better than the other. There are often substantial costs for implementing a
new approach, so if it is not significantly better than another approach, it may not be worth it to
make the change. Third, although some people receive the less effective approach during testing,
if the new approach is superior, that new approach can be provided to everyone once testing is
completed.