4 minute read
4 reasons why compliance training flops—and how to fix it.
July 13, 2021 3:00:00 AM CDT / by Ricardo Pellafone
Did you ever put in a ton of time into creating compliance training and then get frustrated when the end product was a total flop?
As in employees hated it, or worse—they loved it, but it made ZERO impact on their behavior?
Did you ever wonder where it went sideways?
Most of the time we get this wrong. Our industry has focused so much on flashy media and fads that it's easy to miss some of the really basic things we do that can result in terrible training, no matter how much money and time we throw at it.
Now, we've previously discussed what defines good training, and we covered what the Department of Justice is going to look for in your training in our interview with their former compliance counsel expert. Read those first if you haven't, especially the interview.
After that, and after you get on board with the idea that all training needs to be prevention–focused, read the rest of this post. We cover four reasons why your training can flop—even when you have the best of intentions.
Reason #1: You started with format.
“Starting with format” means that you decide to do a video or animation or whatever and then go from there.
This is like saying “we need to buy a boat!” without first looking at a map to see whether you need to travel over water to reach your destination. Maybe you get lucky and it works out ... but more likely you just get stuck with a boat and end up stranded halfway there.
Start with the problem you’re trying to solve. Your problem should sound like “people are doing X, and we need them to do Y instead.” That is a training problem, because training is about directing behavior.
Once you know the problem you are trying to solve, you can pick the right format—and sometimes, you may realize that the right format isn’t training at all, but “we need to hire someone” or “this is actually a discipline problem.”
Reason #2: You obsessed about engagement.
Sure, engagement is important in a really reductive sense—you can’t change someone’s behavior or make them learn something if they don’t notice it in the first place.
But a misplaced focus on “engagement” has led way too many programs down the wrong path, confusing entertainment and training in a way that has generated a cottage industry of well-made-but-totally-useless media.
Can training be entertaining? Sure, but that’s not the goal. The goal is to be useful, not flashy. People will use things that are useful but not entertaining—like, say, a road sign, or a dictionary—but the opposite is not true.
Obsess about transfer—that is, whether employees are applying the information correctly in the real world. You cannot have transfer without engagement, but you can definitely have engagement without transfer. Focus on the right one.
Reason #3: You focused on bad employees.
This one usually sounds like “we don’t want people to click through the training too fast” and results in a bunch of media and clickable junk put in to slow people down.
That is, instead of letting people go through at their own pace—like adults who are actively engaging in the process—it forces them to sit there, passively listening to the world’s slowest voiceover.
This still doesn’t capture your bad employees (they’ll just play on their phone while your training drones on), and it means that you lose your good employees by turning the whole thing into a passive exercise that treats them like children.
Don’t worry about bad employees, because you can’t force grown-ups to learn something against their will. Training is for good employees (as the DOJ's former compliance expert notes in our interview with her), and that's fine because it's only part of your compliance program: controls, policies, auditing, investigations, and discipline are for the bad employees.
Instead of fretting about people who are going to click through without reading, focus on making your training easy to use and let your good employees take as little or as much time as they need; they’re the only ones you can reach in the first place.
Reason #4: You added in “just in case” content.
“Just in case” content is anything you don't actually expect someone to do, but you put in there “just in case.” That is, you want it in there “just in case” something happens, so you can show that you told your employees about it.
This is not training; this is liability shifting, and employees know it.
That is, the goal is not to help them comply; the goal is to shift responsibility to employees so you have catch-all legal grounds to fire them if they screw up, or blame them if a regulator comes knocking.
We all deal with stuff like this every day, and we go along with it, but we do not change our behavior in response. Think, for example, about when you update your phone’s software: do you read the new software user agreement?
No? Me neither. Because I know they don’t really care if I understand it, they just want to shift liability to me, and I accept that risk so I just click “update” and move on.
When you pile on “just in case” information that you don't expect anyone to actually follow, this is what you are doing, and they will respond the same way: by ignoring it, accepting the liability, and moving on.
You cannot catch everything—nor are you required to—so focus on what you can reasonably accomplish so you can enlist employees in the fight to help you out. It is much better that employees get it 80% right than they not even try because the entire thing seemed like a check-the-box farce.
Good news, bad news. The bad news is that compliance training can flop, regardless of your good intentions. The good news is that you *can* fix it if you take a step back and be ruthlessly thoughtful about the problem your training is designed to solve. It's doable, I promise.
And if you want more practical guidance about about good training and how to approach it, don't forget to check out our interview with the DOJ's former compliance counsel expert, and our blog series unpacking how you can integrate that guidance into your compliance program. It's a game-changer.