Online Compliance Training: An Adaptive Approach

Do you recall amemorable teacher who inspired you and helped you to learn something new?Chances are that the teacher focused on one topic at a time and allowed you toutilize your prior life experiences and knowledge.

After introducing themselvesand the concepts they were about to teach, such teachers would have assessedjust how much previous knowledge about the topic you already had. From there,they tailored their learning to your needs and experience—they didn’t justrehash information that you already knew.

Unfortunately, much ofthe training that occurs in organizations these days is repetitive and does nottake into account learners’ prior knowledge and experience. This is especiallyevident in online mandatory compliance training, which often requires staff to undertaketraining on a yearly or biennial basis. This makes the training repetitive andcreates hostility in the learners, further distancing them from the contentthey need to understand.

Why the need for compliancetraining?

Despite compliancetraining’s bad reputation, it is important for organizations to get it right; ifthey don’t, the training can be costly, both financially and from a reputationalviewpoint for the organization and the individual.

Ethics and compliancerated as the top issue that keeps chief legal officers (CLOs) up at night, accordingto a 2016 survey by the Association of Corporate Counsel (ACC), with 71 percentof CLOs rating it as the highest priority (see References).

The main reasonsemployers provide compliance training to employees are:

• To meetminimum legal or regulatory requirements, i.e., the training itself iscompulsory
• To act as an insurance policy shoulda breach occur, allowing employers to defend themselves by having proof thatthey did the best they could to prevent that breach
• To reduce risk in their organization by raising awareness of issues such as the risks of moneylaundering, fraud, insider trading, breaches of privacy and data protectionlegislation, sexual harassment, and so on
• To createa more hospitable, respectful, and ethical workplace

The problem with existingonline compliance training

It seems that more andmore training gets pushed out to staff as governments and regulators pass newlaws and regulations. Increasing the number of training hours is not onlyburdensome on staff, but also costly to their employers. An hour of compulsoryglobal training can cost some multinationals tens of millions of dollars inlost productivity. According to aBusiness Insider article, JPMorgan Chase & Co. has said that, in its mortgagebusiness alone, staff spent 800,000 hours in compliance training in a singleyear (see References).

The traditional,monolithic PowerPoint-like slides, followed by assessment questions, are uninspiring;they contribute to the bad name that compliance training typically garners, theyprovoke pushback from staff, and they often mean that insufficient, if any, learninghas taken place.

There have been cases of staff cheating on their assessments. In late2015, Goldman Sachs and JPMorgan Chase fired staff after discovering they hadcheated on their mandatory internal training exams. Bloomberg Newsreported that their reasons for doing so included that training was “seen astime-consuming and repetitive” (see References). More recently, in January 2017,a senior financial planner at one of Australia’s biggest banks, NAB, was expelledfrom the Financial Planning Association after being found guilty of cheating ona compliance exam by swapping exam papers, according to Australian newspaper The Age (see References).

How can we fix onlinecompliance training?

Some staff may beexperts in a particular topic, or at least have a higher level of knowledge onthe subject. If this is the case and they can prove this, then they should nothave to sit through the specific topic or topics in which they are sufficientlyknowledgeable.

Staff from financialservices organizations, such as banks and financial planners, are all requiredto be trained in regulatory compliance topics such as privacy, insider trading,and money laundering. If a staff member completes their training at one organizationand then starts a similar role at another organization the next year, they wouldnormally be required to complete comparable training. Depending on their levelof competence, this could be a waste of time for both the individual and theorganization.

Despite increasedregulatory activity, organizations need to cut down the number of traininghours their staff undertake. In addition, we need to provide training that isadaptive to the users’ needs and their prior knowledge.

Decreasing the amountof training that a learner must complete gives them more time to learn, andabsorb, new topics and ideas relevant to their job role and responsibilities.

A solution: Adaptive eLearning

For the purposes ofcompliance training, which operates within the context of legal and regulatoryobligations that people must adhere to and fulfill, adaptivity may work bestwhen it’s aligned with the assessment component of the training—that is, whenlearners can demonstrate proficiency in a given topic by answering a series ofquestions. The learner’s answers to these questions will provide data that theprogram will use to dynamically personalize the training to individualstrengths and weaknesses.

The concept of adaptiveeLearning (adaptivity) refers to when a learner’s competency is assessed priorto pushing out the content to them. The content is consequently customized anddelivered to them based on their pre-existing knowledge.

In this context, adaptivityis not related to responsive design—that is, automatically changing what a usersees depending on their device (such as a desktop computer, tablet, orsmartphone)—so much as the content learners are presented with.

Rather than focusingon the competencies that learners already possess, adaptive learning focusessolely on the key areas for improvement.

Adaptivity saveslearners’ time, keeps them engaged, and leads to better learning outcomes thantraditional SCORM-based eLearning solutions.

How does adaptive eLearningwork?

Online compliancecourses should be modular and targeted to specific user groups; for example,courses on competition law and trade practices would require differentinformation for different groups of staff: sales and marketing staff, managers,and general staff. Information security courses may have different content forstaff who work from home or travel often, as opposed to those who aredesk-bound.

Upon entering theonline training course, a staff member will be presented with a pre-assessmentfor a specific topic or module, which may have the same questions that appearin the final course quiz. If the staff member passes the assessment, they willbe able to skip that specific topic or module.

The questions that areasked in the pre-assessment should be based on the learning outcomes for thespecific topic or module. For example, if there are five learning outcomes forone module, then there should be 15 questions in that module’s pre-assessment.

A scenario-based approachto adaptive eLearning

As professionals, weunderstand that drawing on real-world scenarios that are relevant to alearner’s job role can fundamentally enhance our courses. Presenting thelearner with a relatable job-based scenario, asking a question based on thatscenario, and providing instant feedback following the scenario is a part of adaptiveeLearning.

Branching: Creatingpathways

A second level of adaptivitycould include “branching” of the scenarios. For example, whether the scenarioquestion is answered correctly, partially correctly, or incorrectly willdetermine the next screen, or screens, that the learner is presented with. Thesescreens may include a review of the content, or new scenarios and questions toreinforce understanding.

Let’s look at ahypothetical example.

Say I recently startedwork as a bank teller. As part of my induction, I am required to complete ananti–money laundering compliance course. I answered pre-assessment questions,which determined that I need to undertake all modules.

I am presented with areal-life scenario that could easily happen to staff in my bank. After readingthe scenario, I am then presented with interactive content (theory pages) that explainthe concepts further.

I am then presentedwith a question relating to the scenario. I answer it incorrectly and receiveinstant feedback. When I move forward, I am once again taken to the relevanttheory pages to review.

After reviewing thiscontent a second time, I reattempt the scenario question. This time I answer it“partially” correctly, whereupon I am presented with a different, albeitsimilar, scenario and question. (In other topics, I may be presented withadditional information added to an existing scenario.)

Upon answering thisquestion correctly, I can move ahead to the next topic or sub-topic.

How adaptive eLearning willhelp with compliance training

• It identifies staff members’ gaps in knowledge.Compliance managers can tailorfuture training programs based on analytics gathered from pre-assessmentresults throughout the organization.
• It reduces training time. Since users are trained only in the areas inwhich they lack competency, the amount of training time can decreasesignificantly, ultimately saving organizations money.
• It is more engaging for the learners. By focusing on relevant topics that they do notalready know, the learners are more engaged and therefore more likely to retainthe content.

Adaptive learning and thebrain

From a neurologicalperspective, providing learners with connections, such as reflecting on real-lifescenarios, can assist with memory retrieval by getting information fromshort-term into long-term memory. This can happen when the brain searches, or“cross-references,” information we have already stored in our longer-termmemory.

Neuroplasticity

Neurons areelectrically charged cells. The neurons in our brain (the average human brainhas about 100 billion of them) send chemical signals, making connections withother neurons (synaptic connections). When we learn something new, neurons inour brains fire, making make new synaptic connections with other cells. Aslearning and development professionals, we need to ensure that learners gettheir neurons firing.

Failure can aidlearning. One way we can help to “fire up” those neurons is to allow thelearners to fail. Allowing learners to fail by asking more difficultscenario-based questions can help stimulate neural activities—more so than thesuccessful answering of a very simple question. This is because when we take onunfamiliar, difficult, or creative tasks, we’re suppressing the part of ourbrain that directs automatic thinking processes, as Stephanie Castellanoexplains in TD magazine (seeReferences).

Conclusion

Adaptive learning is aconcept that continues to evolve, combining the scalability that eLearning has(in its delivery to learners) with a dynamic sensitivity to individual learners(offering increasingly personalized training to individuals).

By planning anddelivering compliance eLearning using an adaptive and scenario-based approach, anorganization can train its staff only on what they need to know. Consequently,they can absorb information and ideas previously unknown or unmastered by them,and organizations can ensure that their compliance training is not onlyefficient, but also effective.

References

Association ofCorporate Counsel (ACC). ACC Law Department Management Report. 2016.

Castellano, Stephanie.“Neuroscience ‘No-Brainers’ for Trainers.” TD. 9 February 2015.

Danckert, Sarah. “NAB senior planner expelled from Financial Planning Association for cheating.” TheAge. 20 January 2017.

Horta E Costa, Sofia,and Ruth David. “Goldman, JPMorgan Said to Fire 30 Analysts for Cheating on Tests.” Bloomberg. 16 October 2015.