January 20, 2022
Source: Hart Group
Photo Source: Unsplash,
January 18, 2022
Chair of the Public Administration & Constitutional Affairs Committee (PACAC)
Dear Mr Wragg,
Re: Ethical concerns arising from the Government’s use of covert psychological ‘nudges’ in their COVID-19 communications strategy
...The position of the British Psychological Society
The British Psychological Society (BPS) is the leading professional body for psychologists in the UK. According to their website (10), a central role of the BPS is, ‘To promote excellence and ethical practice in the science, education and application of the discipline’. [Our emphasis]. Mindful of their important position as the guardian of ethical psychological practice, on the 6th January 2021 46 psychologists and therapists (including many of the signatories of the present letter) wrote to the BPS (11) raising the ethical questions outlined above.
A month later, on the 5th February 2021, a reply (12) was received from Dr Debra Malpass (Director of Knowledge and Insight at the BPS) which failed to directly address our ethical concerns and was, in our view, evasive and disingenuous. Dr Malpass’s response included questioning whether the strategies deployed by Government psychologists were actually covert, stating that the role of specific psychologists had not been evidenced, and expressing how ‘incredibly proud’ the BPS was about the ‘fantastic work done by psychologists throughout the pandemic’.
Dissatisfied with this initial reaction, we contacted the BPS again to question whether our expressed concerns had actually been considered by their ethics committee. We received a brief reply from Dr Malpass on the 16th February 2021 informing us that our initial letter would be considered at their next BPS Ethics Committee on the 1st March; we understood this to be an admission that the covert psychological strategies recommended by psychologists had yet to be scrutinised in regards to their ethical acceptability.
By 12th March, and not having received any further communication from the BPS, we prompted them again. On the 23rd March a message was received from Dr Roger Paxton (Chair of the BPS Ethics Committee) apologising that ‘owing to a very full agenda and an oversight’ no discussion about our concerns had taken place but that they would be included on the agenda of their June meeting.
On the 30th June, and not having received any further communication from the BPS, we prompted them again. On the 1st July we received a response (13) from Dr Paxton, comprising three paragraphs, informing us that the issues we raised had been considered and that their ethics committee had endorsed all previous BPS responses. In this communication, Dr Paxton acknowledged that he had received a large number of recent emails raising the same issues, but rejected our ethical concerns arguing that the strategies referred to were ‘indirect’ rather than covert, the application of psychology in this instance fell outside the realm of individual health decisions (so informed consent was not an issue), levels of fear within the general population were proportionate to the objective risk posed by the virus, and the psychologists’ role in the pandemic response demonstrated ‘social responsibility and the competent and responsible employment of psychological expertise’.
We believe the BPS responses to our ethical concerns about the deployment of covert psychological strategies throughout the COVID-19 pandemic have been defensive and disingenuous. Also we believe the BPS is impeded by a major conflict of interest on this issue in that several members of the SPI-B are also influential figures within the BPS. As such, the impartiality of the BPS in addressing the ethical issues we raised is highly questionable.
Finally, it is worth noting that serious concerns about the Government’s use of behavioural science have previously been raised in relation to other spheres of government activity. An All Parliamentary Group Report (APGR) (14) analysing the recommendations of the Morse Report (15) (a Treasury-commissioned review into the Loan Charge, published in December 2019) found that the distress evoked in those people targeted by behavioural insights may, in some instances, have led to victims taking their own lives. In the words of the APGR:
‘HMRC continue to apply pressure to taxpayers by using 30 behavioural insights in communications, something that has been cited in one of the seven known suicides of people facing the Loan Charge’.
In further recognition of the suffering and anguish associated with these ‘nudge’ techniques, the APGR recommends:
‘An independent assessment and suspension of HMRC’s use of behavioural psychology/behavioural insights in light of the ongoing suicide risk to those impacted by the Loan Charge’.
Clearly, a truly independent and comprehensive evaluation of the ethics of deploying psychological ‘nudges’ on the British people – during public health campaigns and in other areas of government – is now urgently required. We respectfully ask the PACAC to consider performing this important role.
Co-Signatories
Psychology/therapy/mental health
Dr Gary Sidley (M.Sc., ClinPsy, PhD) Retired Consultant Clinical Psychologist
Ms Jen Ayling (UKCP registered counsellor) Psychotherapeutic Counsellor
Dr Faye Bellanca (DClinPsy) Clinical Psychologist
Dr Christian Buckland ((PsychD) Psychotherapist
Alison Burnard (Dip Gestalt Therapy) Gestalt Psychotherapist
Daran Campbell (PG Dip Counselling) Substance Misuse Practitioner
Dr Tom Carnwath (FRCPsych, FRCGP) Consultant Psychiatrist
Dr Maria Castro Romero (DClinPsy) Senior Lecturer in Clinical Psychology
Gillian England (PG Dip Cognitive Behavioural Psychotherapy) Cognitive Behavioural Therapist
Dr Elizabeth English (M.Phil, DPhil) Mindfulness Teacher & Trauma Therapist
Mr Patrick Fagan (M.Sc.) Chief Scientific Officer, Capuchin Behavioural Science
Dr Tracey Grant Lee (DClinPsy) Chartered Clinical Psychologist
Andy Halewood (Advanced M.Sc. in Counselling Psychology) Chartered Psychologist
Sue Parker Hall (CTA, MSc, PGCE) Psychotherapist
Andrew D Harry (RPP PTP) NLP Master Practitioner
Mrs Nicole Harvey (B.Sc, Pg Dip) Mental Health Practitioner/CBT Therapist
Ms Julie A Horsley (Advanced Diploma in Counselling) Counsellor/Therapist
Dr Richard House (MA, Ph.D, C.Psych. AFBPsS) former Senior Lecturer in Psychology
Emma Kenny (MA Counselling, Advanced Diploma Counselling) Media Psychologist & Psychological Therapist
Rachel Maisey (MA, PGCE, PgDip Counselling) Integrative Counsellor
Jane Margerison (PG Dip Integrative Psychotherapy, RMN) Psychotherapist
Kate Morrissey (Advanced Diploma in Counselling, MA Social Work) Counsellor
Lucy Padina (Diploma in Psychology, Advanced Diploma in the Management of Psychological Trauma) Independent Consultant & Registered Social Worker
Carolyn Polunin (M.Sc.) Integrative Psychotherapist
Dr Livia Pontes (DClinPsy) Clinical Psychologist
Dr Kate Porter (DClinPsy) Clinical Psychologist
Ian Price (M.Sc. Organisational Behaviour) Business Psychologist
Dr Bruce Scott (B.Sc., PhD) Psychoanalyst
Professor David Seedhouse (PhD) Honorary Professor of Deliberative Practice
Deborah Short (MA Gestalt Psychotherapy) Psychotherapist
Ms Deborah Sharples (B.A. [Hons] Social Work) Mental Health Social Worker
Susan Sidley (RMN) Retired Psychiatric Nurse
Dr Angela Smith (DClinPsy, PhD) Psychology Lead
Dr Helen Startup (DClinPsy, PhD) Consultant Clinical Psychologist
Dr Dov Stein (MA, MB, BCh, BAO DCH Dobs) Consultant Psychiatrist & Psychotherapist
Dr Zenobia Storah (DClinPsy) Child & Adolescent Clinical Psychologist
Professor Ellen Townsend (PhD) Professor of Psychology
Sarah Waters (BA, Dip Counselling & Therapy) Psychotherapist
Dr Alice Welham (MA, DClinPsy, PhD) Clinical Psychologist
Dr Damian Wilde (DClinPsy) Highly Specialist Clinical Psychologist
Other health professionals
Mr John Collis (PGCert in Advanced Practice, BSc [Hons] Nursing, BA [Hons] Retired Nurse Practitioner
James Cook (Bachelor of Nursing [Hons], Master of Public Health [MPH]) Registered Nurse
Dr Clare Craig (BM, BCh, FRCPath) Consultant Pathologist
Dr David Critchley (BSc, PhD) Clinical Pharmacologist
Roisin Dargan-Peel (MA) Former Registered General Nurse, Midwife & Health Visitor
Mr Paul Goss (MCSP, HCPC, KCMT) Clinical Director & Chartered Physiotherapist
Dr Ros Jones (MD, FRCPCH) Retired Consultant Paediatrician
Mrs Alison Langthorne (RGN) Staff Nurse
Jenna Leith (RGN) Advanced Nurse Practitioner
Dr Sam McBride (MB, BCh, MRCP, FRCP, FRCEM) Clinical Gerontologist
Mrs Julie Noble (M.Sc, RN) Senior Forensic Nurse Examiner & Advanced Practitioner
Mrs Christine Mary Proctor (RGN) Former Registered General Nurse
Dr Annabel Smart (MBBS, BSc, DFSRH) Retired General Practitioner
Nat Stephenson (B.Sc Audiology) Paediatric Audiologist
Dr Helen Westwood (MBChB, MRCGP, DCH, DRCOG) General Practitioner
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