Online Compliance Training: An Adaptive Approach

Written By

Lyndon Lovell

March 06, 2017

Do you recall a memorable 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 to utilize your prior life experiences and knowledge.

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

Unfortunately, much of the training that occurs in organizations these days is repetitive and does not take into account learners’ prior knowledge and experience. This is especially evident in online mandatory compliance training, which often requires staff to undertake training on a yearly or biennial basis. This makes the training repetitive and creates hostility in the learners, further distancing them from the content they need to understand.

Why the need for compliance training?

Despite compliance training’s bad reputation, it is important for organizations to get it right; if they don’t, the training can be costly, both financially and from a reputational viewpoint for the organization and the individual.

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

The main reasons employers provide compliance training to employees are:

  • To meet minimum legal or regulatory requirements, i.e., the training itself is compulsory
  • To act as an insurance policy should a breach occur, allowing employers to defend themselves by having proof that they 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 money laundering, fraud, insider trading, breaches of privacy and data protection legislation, sexual harassment, and so on
  • To create a more hospitable, respectful, and ethical workplace

The problem with existing online compliance training

It seems that more and more training gets pushed out to staff as governments and regulators pass new laws and regulations. Increasing the number of training hours is not only burdensome on staff, but also costly to their employers. An hour of compulsory global training can cost some multinationals tens of millions of dollars in lost productivity. According to a Business Insider article, JPMorgan Chase & Co. has said that, in its mortgage business alone, staff spent 800,000 hours in compliance training in a single year (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, they provoke pushback from staff, and they often mean that insufficient, if any, learning has taken place.

There have been cases of staff cheating on their assessments. In late 2015, Goldman Sachs and JPMorgan Chase fired staff after discovering they had cheated on their mandatory internal training exams. Bloomberg News reported that their reasons for doing so included that training was “seen as time-consuming and repetitive” (see References). More recently, in January 2017, a senior financial planner at one of Australia’s biggest banks, NAB, was expelled from the Financial Planning Association after being found guilty of cheating on a compliance exam by swapping exam papers, according to Australian newspaper The Age (see References).

How can we fix online compliance training?

Some staff may be experts in a particular topic, or at least have a higher level of knowledge on the subject. If this is the case and they can prove this, then they should not have to sit through the specific topic or topics in which they are sufficiently knowledgeable.

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

Despite increased regulatory activity, organizations need to cut down the number of training hours their staff undertake. In addition, we need to provide training that is adaptive to the users’ needs and their prior knowledge.

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

A solution: Adaptive eLearning

For the purposes of compliance training, which operates within the context of legal and regulatory obligations that people must adhere to and fulfill, adaptivity may work best when it’s aligned with the assessment component of the training—that is, when learners can demonstrate proficiency in a given topic by answering a series of questions. The learner’s answers to these questions will provide data that the program will use to dynamically personalize the training to individual strengths and weaknesses.

The concept of adaptive eLearning (adaptivity) refers to when a learner’s competency is assessed prior to pushing out the content to them. The content is consequently customized and delivered to them based on their pre-existing knowledge.

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

Rather than focusing on the competencies that learners already possess, adaptive learning focuses solely on the key areas for improvement.

Adaptivity saves learners’ time, keeps them engaged, and leads to better learning outcomes than traditional SCORM-based eLearning solutions.

How does adaptive eLearning work?

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

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

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

A scenario-based approach to adaptive eLearning

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

Branching: Creating pathways

A second level of adaptivity could include “branching” of the scenarios. For example, whether the scenario question is answered correctly, partially correctly, or incorrectly will determine the next screen, or screens, that the learner is presented with. These screens may include a review of the content, or new scenarios and questions to reinforce understanding.

Let’s look at a hypothetical example.

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

I am presented with a real-life scenario that could easily happen to staff in my bank. After reading the scenario, I am then presented with interactive content (theory pages) that explain the concepts further.

I am then presented with a question relating to the scenario. I answer it incorrectly and receive instant feedback. When I move forward, I am once again taken to the relevant theory pages to review.

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

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

How adaptive eLearning will help with compliance training

  • It identifies staff members’ gaps in knowledge. Compliance managers can tailor future training programs based on analytics gathered from pre-assessment results throughout the organization.
  • It reduces training time. Since users are trained only in the areas in which they lack competency, the amount of training time can decrease significantly, ultimately saving organizations money.
  • It is more engaging for the learners. By focusing on relevant topics that they do not already know, the learners are more engaged and therefore more likely to retain the content.

Adaptive learning and the brain

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

Neuroplasticity

Neurons are electrically charged cells. The neurons in our brain (the average human brain has about 100 billion of them) send chemical signals, making connections with other neurons (synaptic connections). When we learn something new, neurons in our brains fire, making make new synaptic connections with other cells. As learning and development professionals, we need to ensure that learners get their neurons firing.

Failure can aid learning. One way we can help to “fire up” those neurons is to allow the learners to fail. Allowing learners to fail by asking more difficult scenario-based questions can help stimulate neural activities—more so than the successful answering of a very simple question. This is because when we take on unfamiliar, difficult, or creative tasks, we’re suppressing the part of our brain that directs automatic thinking processes, as Stephanie Castellano explains in TD magazine (see References).

Conclusion

Adaptive learning is a concept 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 and delivering compliance eLearning using an adaptive and scenario-based approach, an organization 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 only efficient, but also effective.

References

Association of Corporate 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.The Age. 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.

Oran, Olivia. “Bankers are worried that Trump will scrap Wall Street regulation.Business Insider. 28 November 2016.

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