The confidentiality requirements of a change initiative profoundly affect how change managers can communicate, engage stakeholders, and build awareness and desire for the change. Understanding and correctly documenting confidentiality constraints is an essential component of communications and engagement planning.
Definition and Distinction
Confidentiality level in the change management context refers to the degree to which information about the project—its existence, objectives, scope, timeline, or likely impacts—must be restricted from certain audiences during some or all the project lifecycle. This is distinct from general information security classification (which applies to data and documentation) and from communication embargo periods (specific windows during which no external communications may occur).
Confidentiality requirements in change management arise from several sources: ASX or stock exchange listing obligations (which may prohibit disclosure of material, price-sensitive information before official announcement); merger, acquisition, or restructuring sensitivity; commercially sensitive negotiations with third parties; or internal cultural norms about managing employee expectations.
Why Confidentiality Level Matters for Change Management
Confidentiality constraints directly affect the sequence and content of change management activities. When strict confidentiality is required, change managers cannot conduct early stakeholder engagement and awareness-building activities that are most effective in reducing resistance. This compression of the change journey increases adoption risk and must be explicitly managed.
Confidentiality requirements also affect the design of the change agent network and the briefing of business unit leaders. Leaders who must manage their teams' questions and concerns cannot do so effectively if they themselves have not been briefed. Change managers must negotiate with the project sponsor to determine the minimum set of stakeholders who can be briefed earlier than the general population, and under confidentiality conditions.
Assessing and Documenting Confidentiality Level
Change managers should assess confidentiality requirements by consulting with the project sponsor, legal or compliance counsel, and the communications function. The assessment should produce a clear understanding of what information is confidential; who may access confidential information and under what conditions; and the planned announcement timeline after which information may be more broadly shared.
Example of a well-documented confidentiality assessment:
The project involves a proposed organisational restructure affecting approximately 200 roles. All information regarding role changes is classified as strictly confidential until the formal announcement, planned for 15 March. A tiered disclosure schedule has been agreed: the Executive Committee will be fully briefed on 1 March; People Leaders of affected teams will be briefed under embargo on 13 March; all employees will be informed simultaneously on 15 March. All change management activities before 15 March must be conducted without reference to the role changes.'
Common Pitfalls and How to Avoid Them
· Underestimating the compliance risk of premature disclosure: In regulated environments, premature disclosure of material non-public information can have serious legal consequences. Change managers must not treat confidentiality requirements as advisory.
· Failing to plan for the post-announcement communication surge: After a confidentiality embargo is lifted, stakeholders will require rapid, comprehensive information. Communication materials, Q&A documents, and leader briefing packs should be prepared in advance of the announcement date.
· Not briefing leaders at the earliest permissible opportunity: People leaders who are not briefed before a general announcement are unable to support their teams effectively. Negotiate the earliest possible leader briefing consistent with confidentiality obligations.
· Treating all project information as equally confidential: Not all project information will be equally sensitive. A segmented approach—identifying what is strictly confidential, what can be shared on a need-to-know basis, and what can be broadly communicated—allows change managers to conduct more effective preparatory activities.
References
Australian Securities Exchange. (2013). ASX Listing Rules: Continuous Disclosure. https://www.asx.com.au/regulation/rules-guidance-notes-and-waivers/asx-listing-rules.htm
Prosci. (2023). Communications Planning in Change Management. https://www.prosci.com/resources/articles/change-management-communications
Bridges, W. (2009). Managing Transitions. Da Capo Press. https://wmbridges.com/books/managing-transitions