Proactive Client Disclosure & Informed Consent
This criterion assesses the organization's commitment to proactive, clear, and comprehensive communication with clients, ensuring they are fully informed and empowered to make sound decisions. It evaluates the extent to which the organization goes beyond minimum legal requirements to provide easily understandable information about services, fees, risks, and potential conflicts of interest. The aim is to ensure clients have genuine informed consent (Rida), enabling them to participate in financial/professional relationships based on trust, transparency, and a clear understanding of their rights and obligations. This encompasses the entire client lifecycle, from initial engagement to ongoing service delivery, with a particular focus on vulnerable clients or complex services. The organization should actively seek to bridge any information asymmetry and empower clients through education and open dialogue, fostering a relationship built on mutual respect and fairness. Communications must avoid concealing the truth (Qur'an 2:42), embody truthfulness (Sidq), and prevent harm (La darar wa la dirar) by pausing transactions if comprehension is lacking.
| Metric | Composite Transparency Score |
|---|---|
| Target | Comprehension ≥90% (overall) / ≥85% (vulnerable); Readability ≤ Grade 8; Complaints <2 per 1,000. |
| Frequency | Quarterly |
| Method | Triangulation of: (1) % Clients passing objective comprehension check; (2) Readability score (Flesch-Kincaid); (3) Complaints per 1,000 clients related to clarity. |
| Unit | Composite Score |
Level 1: Initial/Ad-hoc
Disclosure practices are ad-hoc and reactive. Information is jargon-heavy, no comprehension testing is performed, and conflicts are not systematically managed. Potential for misleading clients or concealing defects (ghish).
Level 2: Developing
Standardized processes exist, but templates may be outdated (poor version control). Vulnerability handling is ad-hoc. Conflicts register exists, but engagement-level disclosure is inconsistent. No specific accessibility SLAs.
Level 3: Established
Proactive disclosure using standardized 'Key Facts Summary' templates. Conflicts disclosed in writing. Initial comprehension checks used for high-risk services. Meets minimum regulatory requirements (CCR, GDPR, Sector rules). Accessibility requests handled on best-effort basis.
Level 4: Advanced
Systematic measurement of comprehension with defined targets (e.g., ≥90%). Vulnerability triage active with tailored plans. Conflict mitigation hierarchy enforced. Digital channels WCAG compliant. Material changes trigger re-consent reliably. Board reviews disclosure MI.
Level 5: Optimizing
Exemplary. Closed-loop improvement driven by deep analysis of comprehension data and complaints. Independent audits confirm clarity. 'Known Limitations' box standard. Teach-back used in 100% of high-risk cases. Accessibility SLAs consistently met. Fully embodies Ihsan and Nasihah.
Organisation Types
By Organisation Size
| Size | Applicability | Notes |
|---|---|---|
| Micro | exempt | Formal RACI frameworks, 2nd line assurance, and comprehension testing are entirely disproportionate for volunteer-run groups. |
| Small | partial | Formal RACI and 2nd line compliance are disproportionate; applies only to basic clear communication and avoiding jargon (Ghrar). |
| Medium | partial | May lack a dedicated 2nd line compliance function; scales down to Key Facts Summaries, clear language, and basic board reporting. |
| Large | full | |
| Major | full |
Applicable When
- The organization provides financial or professional services to clients.
- Client decisions are significantly impacted by the information provided by the organization.
- The services involve financial transactions, legal advice, or healthcare decisions.
Not Applicable When
- Not applicable only where there is no client decision-making and no material risk (e.g., fully automated, non-personalized, zero-risk information services). Pro bono services in legal/healthcare remain in scope for informed consent and disclosure.
Related Criteria
Discussion (1)
📋 **Version updated: 1.0.0 → 2.9.7** **Changes:** Full import from mizan-297.json
Sign in to post a comment.