Compliance training: The single biggest mistake you’re making

At what point did we enter the warehouse store model of compliance training?

Imagine this. It’s a Saturday morning, and you’re off to run your errands. On your list? A marinated tri-tip from that warehouse store up the road. It’s a crowd pleaser. Except you don’t leave said big-box store with just the tri-tip. Rather, your cart is filled to the brim with a thirty-pound bag of Twizzlers, a six-pack of folding chairs in case you have an influx of relatives with nowhere to sit, and a 96-count of paper towels. As the fog wears off and the dust settles, you only realize the extent of your “one item trip” when you get home and have a “what just happened!?” moment.

My PSA: I am a compliance leader responsible for the oversight of my organization’s ethics and compliance program. I use training as a lever to help employees do their jobs the right way. I also happen to work for a learning technology company that delivers smarter learning in the form of adaptive compliance courses that provide rich, actionable insights.

As you survey the solutions provider landscape, it may be tempting to secure an “extensive library” with thousands and thousands of titles. It sounds appealing because the warehouse store (or even the all-you-can-eat buffet that offers more than you care to eat) effect creeps in. It speaks to us like…

“Well, you don’t really need it…but it’s right there… and there’s a lot of it… so that must be a better value!”

It’s as if an uncontrollable deeply rooted psychological phenomenon occurs that causes a visceral fight or flight reaction. (Wow! That’s a mouthful of big words and jargon. It sounds really impressive, but there’s bound to be a simpler way to get the message across and make it more impactful…)

When you get down to it, you’re only going to use a handful of those courses per year. What’s most important is the experience your employees have and the actionable analytics you’ll gain to continuously improve your compliance program.

No matter what “compliance training vendor” you partner with, the DOJ isn’t going to be impressed with the fact that you have endless titles you may decide to deploy on a rainy day. What they actually care about is that you trained your high-risk folks on the compliance issues they’ll face in the course of their jobs, and that you did it in an effective manner.

Before you head down this too-many-options, not-enough-impact route, ask yourself these four questions…

1. What specific risk areas do I need to train employees on and why?

I say “specific” because this will be specific to your industry and the risks that come along with the way your organization does business. Aside from the compliance training you are required to deploy per regulatory requirements, identify what your employees really need by looking at your compliance risk assessment and other types of information like helpline, legal, operational outcomes, audit data, and even what’s happening in your industry vertical.

This step alone may take some time depending on what you know and the information you have—and because it requires you to get out from behind your desk and go on a listening tour with stakeholders across your organization to understand what’s risky and why. You may hear this commonly referred to as the “what’s keeping you up at night?” discussion.

Focus on your objectives: What do you need people to learn or understand? What behaviors should employees demonstrate? Work backwards from there. You may find that not every risk requires e-learning, but rather in-person events, general communications and guidance, or other modalities of delivering information.

2. Who do I need to train?

Who you train is directly correlated with the risk areas you identify in Step 1. To use the words of a wise former boss, we’re not out to “peanut butter spread” training on everyone. It would purely be a check-the-box program if we did. Target training audiences to the risky tasks your employees are doing.

Per the Evaluation for Corporate Compliance Programs (ECCP), you’ll also need to evaluate whether supplemental compliance training is required for supervisors, gatekeepers in the control process, and those with approval authority or certification responsibilities. The more you can target the employees who need to know specific concepts based on their roles, the more relevant your training is. Did I mention it’s important to target, target, target?

3. Will training data help me identify areas that need more guidance?

While you might have stellar completion rates, that doesn’t tell you whether employees understand the behaviors expected of them. Your compliance training should generate predictive, actionable data that gives you a window into what your employees know and where they need additional coaching and feedback in simulation—so that you can provide targeted (there’s that word again) guidance to those who need it. Not getting this type of information is like deploying training and just hoping that people get it.

Compliance guidance is a cyclical, responsive exercise: we need to consider it part of our ecosystem of human behavior reinforcement. This is where we can bring in lessons learned and other important messaging throughout the year to keep the compliance drip relevant.

4. Can I demonstrate the efficacy of my training?

It’s one thing to have predictive training data as I described above. It’s another thing altogether to leverage the data and put it to use to improve and evolve your program in a quantitative way. This part takes work, and it’s frankly also where the “we’re short staffed!” or “we have no budget!” arguments creep in. I’ve seen this done immensely well with a small but mighty compliance group of two, and just OK with a group of 10. The point is, (1) you need data to even think about demonstrating efficacy and (2) be prepared to put in the work to have an impactful program.

Only after you and your team have reaffirmed your true priorities (aka the lone tri-tip on the list and not the 96-count paper towels) should you take the next step. Proceed judiciously.

Speak to a compliance expert

My colleagues at Learning Pool are here to help you deliver targeted training to your employees. We do that by adapting the level of difficulty, providing alternate scenarios, and switching up the activities to each individual in real-time. Our approach guarantees topic mastery in as little time as possible, and gathers analytics that gives you actionable behavioral insights and helps you with board reporting. Request a demo to learn more today.