Changing expectations for compliance training

How do you prove training effectiveness and measure risk avoidance as regulatory scrutiny and business pressures continue to rise?

To consider a compliance program successful (or even satisfactory), ongoing training must be an integral component of the program. However, merely its inclusion is not enough; the training must be effective. But how do you prove effectiveness and measure risk avoidance as regulatory scrutiny and business pressures on organizations continue to rise? As expectations rise, it can be challenging to keep up.

Many organizations use a “check the box” training approach because effective measurement has been out of reach for most compliance programs. If a training program exists and employees participate, it is thought to be satisfactory. Completion records, policy attestations, and employee satisfaction surveys are seen as measurement and proof of success. However, completion is not a gauge of effectiveness, and many companies now consider this approach outdated and insufficient.

Regulatory focus on anti-corruption training demonstrates this. Representatives from the Department of Justice and
Securities and Exchange Commission are clearly signaling that employee signatures on completion certificates are no longer sufficient. Regulators want companies to demonstrate the effectiveness of their training… and this is just the beginning. Take, for example, cybersecurity: nearly half of all data breaches are a result of employee or contractor negligence. According to data from True Office Learning’s I.Q. portal, 43% of employees are unable to identify the proper way to store confidential information when traveling, and this is a trainable opportunity.

A data-driven approach to designing compliance programs sets the foundation for evaluating training effectiveness. This begins with promoting training that has engaging content (i.e., through video) that draws learners in and will pay dividends in improved outcomes on the back end. Where compliance analytics used to consist of course completions, hotline data, and incident reports, they only provide limited insight.

The next generation of compliance training provides robust, insightful data that measures the true efficacy of training efforts and also identifies risk hot spots to address and mitigate risk before it becomes a larger issue. A data-driven approach to training produces fundamental decisions and actions that shape and guide what a training program is, who it serves, what it does, and why it does it — all with a focus on the future.

Organizations that build a measurable, effective training program set priorities, focus resources, ensure employees are working toward common goals, establish agreement around intended outcomes, and assess and adjust the organization’s direction in a changing environment. Data-driven planning considers not only where an organization is going and the actions needed to make progress, but also how it will know if it is successful. By using a strategic, data-driven approach, organizations can best plan, execute, and measure their training programs.

Planning

Strategic planning for training includes determining what topics should be included in training to satisfy the needs of the organization.

Those needs are likely some combination of:

  • Instructing on doing business in the desired manner (culture, revenue, and behavior)
  • Reducing risks
  • Driving behavioral change
  • Satisfying regulatory requirements

Regulatory focus or requirements often mandate specific training topics. However, reputational risk, operational risk, new or evolving risks, and business risks dictate other topics within training. Since organizational risks continue to grow in scale and complexity, it is critical to identify and prioritize risk areas to better focus training.

Companies that take a proactive approach use data to help with this prioritization; they use quantifiable analytics from past training or assessments to drive plans. Taking a reactive approach to identify gaps and risks by using compliance failings, anecdotal evidence, or guessing is viewed unfavorably both internally within organizations and externally.

Executing

Strategic planning for training includes determining what topics should be included to satisfy the needs of the organization.

Those needs are likely some combination of:

  • Increasing learner retention
  • Changing behavior
  • Reducing training fatigue and cognitive overload

If training is too generic, it becomes irrelevant. The more training is directed to a specific audience and their specific needs, the more useful it is. Companies need to understand their audience, know as much as possible about them, and use engaging content and awareness tools that generate interest before and after training to maximize engagement, increase applicability, and raise total education ROI.

Rather than doing the same training every year, provide learners who demonstrate proficiency with more advanced (or possibly abbreviated) training. An organization should know which employees have a lower proficiency in order to adequately address knowledge gaps. This helps an organization focus on areas that employees don’t understand in practical application. To make training more compelling and reduce the tedious nature of traditional methods, captivate the audience with scenario-based storytelling. This allows learners to see how information and decisions fit into real-world applications, and exemplifies the impact of day-to-day choices.

Requiring decisions in scenario-based training enables learners to actively participate in gaining and applying knowledge. This approach is more engaging than presenting large quantities of information and expecting learners to absorb content. Another method to increase engagement is appealing to one’s competitive nature by providing consequences: increase motivation with scoring or benchmarking participants.

Measuring

A strategic approach to training evaluates its effectiveness, uses the results to make necessary changes, and strengthens the overall program. In the most general sense, evaluating training programs using similar standards to compliance programs is worthwhile.

  • This often includes determining whether the program is:
  • Tailored rather than one-size-fits-all
  • Targeted to roles and responsibilities of learners and proficiency levels
  • Customized to complement the existing business operations
  • Reviewed regularly to see if it is working
  • Changed if it is not working
  • Focused on learner engagement and knowledge retention
  • Addressing evolving risks

Measuring these criteria and demonstrating results can be challenging, but it is not nearly as difficult as it once was. Many companies are moving away from subjective appraisals and, instead, are using more objective and quantifiable standards to determine training effectiveness. Metrics and analytics help determine areas of improvement in the program so companies can gauge proficiency, map training to identified knowledge gaps, and measure change year-over-year.

Awareness & Reinforcement

Equally important to formal training is to drive retention throughout the year by reinforcing training concepts. Remind your team about core training concepts throughout the year to spark recognition, solidify understanding, and keep compliance top-of-mind. Using short videos that present unique and relatable compliance situations helps set the right tone, provide context, and promote a “speak up” culture.

Summary

Training as part of an overall compliance program has been a standard for many years. However, traditionally acceptable approaches are now becoming obsolete — internal and external pressures are forcing companies to reevaluate how they train and whether that training is effective. Using a strategic approach and new tools, techniques, and practices is helping many organizations satisfy these standards.

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