A subpar compliance training program could uncoil several risks on a company: damaged corporate reputation, expensive investigations and protracted legal actions, not to mention the ire of regulatory agencies.
Those risks raise the bar on the due diligence companies must perform on any organization they consider to provide outsourced online training to employees. “Compliance training is a high-stakes process for all organizations,” says M.J. Hall, content manager at the Association for Talent Development Forum. “While almost all training is evaluated for content, approach, and delivery and measured for impact, compliance training is under even more scrutiny.”
A first step is identifying the primary risks that, if realized, could harm the company, and the education needed to mitigate these exposures, says Hall. Armed with this information, the compliance department can set out a “buy or build” analysis.
When it comes to compliance training, many companies mix the two. Third-party online training provides “the greatest leverage with topics that are pretty common and broad-based,” such as bribery and conflicts of interest, says Kirsten Liston, associate vice president, learning content strategy at SAI Global. Most providers have courses on these topics that already have been broadly deployed, and then modified and enhanced based on feedback from previous users. “Why pay to develop a custom solution when other companies have already done this and answered the same questions?” Liston asks.
Third-party online solutions also can make sense when the training needs to be delivered to employees around the globe, Hall says. It’s often more efficient to use a tested off-the-shelf solution that has already been translated into several languages than to develop and deliver a custom program.
At the same time, in-house solutions have a legitimate role to play, say compliance training experts. They’re especially valuable when a course needs to cover a procedure that’s unique to the organization, or when the information to be conveyed is complicated and detailed, or applies just to a small sub-set of employees. Liston provides an example: Training, for example, to communicate specific security procedures for IT professionals in the organization could be ripe for in-house development, says Liston.
Of course, before developing online training solutions, organizations need to hire the subject matter experts and instructional designers and purchase the technology tools required to both develop and update the material in a timely manner. The commitment required to create the content and to keep it relevant are the biggest disadvantages of internal development, says Ingrid Fredeen, vice president of advisory services at NAVEX Global. “You need to manage the content, make updates, and ensure it properly reflects the organization.”
Checking Under the Hood
Once an organization has made the decision to work with a third party’s online training solutions, some due diligence is in order. Fortunately, it’s possible to get a handle on providers’ qualifications even before approaching them, Hall notes. Compliance professionals can ask for recommendations via online forums and social media sites, or they can seek opinions from other members of their professional associations.
As an organization narrows its search to several vendors, the due diligence should become more specific. Among the questions to ask: Who are the vendor’s current clients? What sort of results are they achieving with the product? And what metrics is the vendor using to measure performance? Consider it a red flag if a vendor won’t provide any of this information, say training advisers.
“You need to manage the content, make updates and ensure it properly reflects the organization.”
Ingrid Freeden, VP of Advisory Services, NAVEX Global
Of course, the qualifications of the vendor’s staff are critical. Most compliance training materials require a review by legal professionals who can intelligently judge their accuracy. For instance, those who assess the accuracy of a course on Brazil’s Clean Companies Act should be experts on the law, as well as on its background and application.
The provider should stand behind its material, Fredeen says. If the organization deploying the courses becomes involved in a legal action in which the credibility of its training becomes an issue, the provider should be ready to confirm that the course content is accurate and has been appropriately reviewed.
Taking a Test Drive
Along with accuracy, training materials need to be relevant and engaging. Otherwise, employees may lose interest before they gain a solid understanding of the material.
That can present challenges for compliance professionals, who often come to e-learning with a law school mentality. They’re used to reading case law and picking apart details, Fredeen says. Few other employees will need to understand the information at that level, she adds.
To ensure that a training course will hold most employees’ attention and effectively convey information, it helps to partner with experts who understand how adults learn. They can identify material that is dry, overly simplistic, or not relevant, and thus unlikely to engage course participants. “Check with people who aren’t readers,” Liston suggests. How willing are they to sit through the lesson?
One way that training can capture attention and boost engagement is by applying the concepts to real situations through case studies and role-playing scenarios. “Training is not effective if it’s just listing the law. You have to bring it to life,” Fredeen says.
When deploying training across large swaths of employees, it also helps if the provider can offer sessions of varying length, Fredeen says. A shorter course can be used for employees who need just an overview of the topic, and a longer one reserved for those who require more in-depth information.
Tools like glossaries and frequently asked questions also can help employees quickly understand the material, Hall adds. Pre-tests, or quizzes employees take before starting a course, can give them an idea of the material they need to focus on, while post-course tests can, of course, help employees and managers assess how well they understand the information once they’ve completed the course.
WORKING WITH OTHER DEPARTMENTS
Below Karen Kroll asks experts: Does it make sense for compliance to combine its online training with the training efforts underway in other departments? The answer: it depends.
Combining forces can stretch the organization’s investment and lead to consistent content across the regions, says MJ Hall, Ph.D, content manager for the ATD Forum with the Association for Talent Development.
For some organizations, however, the needs of each department are too different to make a joint effort effective. Compliance training often is more complex and must meet requirements that don’t come into play with courses that, say, instruct employees on a new word processing program.
Kirsten Liston, associate vice president, learning content strategy with SAI Global Compliance says that she has worked with organizations that ask employees to rate the training courses they take. However, if their compliance training often is mandatory, while the other courses aren’t – which often is the case – it doesn’t make sense (and can send a confusing message) to have employees rate the courses they are required to take. “Compliance learning benefits as a whole from letting others in on (training), but needs to make sure it works for compliance,” Liston says.
Although using third-party training tools help organizations avoid much of the expense and time required to develop custom solutions, most still need some ability to tailor the material. For instance, they may want to insert their code of ethics into the training materials, or include examples tailored to their industry. Ask how difficult, expensive, or disruptive customization will be, Liston says. “Will the company make it easy or will they fight you?”
How Does It Handle?
When it comes to the technology behind online compliance training courses, many compliance professionals will want to tap into the expertise of their IT colleagues. “Get IT involved early on,” Fredeen recommends.
They can check that the organization’s network is robust enough to handle the system, says Lisa Orndorff, HR manager with the Society for Human Resource Management. The IT experts should also know if the system will need to work with a specific Internet browser, such as Google Chrome. Compliance, IT and the vendor should work together to determine the point of contact for any technical issues employees run into, she adds.
In addition, IT can check that the system has the reporting capabilities the organization needs, Fredeen says. Compliance professionals at organizations with learning management systems (LMSs) should check that their LMSs will support the courses they’re considering.
And although it’s easy to get drawn in by cutting-edge courses that boast exciting multi-media special effects, compliance professionals also need to ensure that they’ll be able to implement and update the training in a reasonable amount of time, Liston says. The flashier e-learning courses can consume more time and resources than their plainer counterparts.