12/06/19
Competent compliance, a nudge in the right direction
Mandatory compliance training is a fundamental part of learning and development provision for most businesses. The particular flavour will depend on the sector, but everyone is familiar with essentials like health and safety, information security, financial conduct, infection control and food handling. Whatever the specific requirement, the goal is to build competencies that really matter, the core competencies that underpin good practice, keep people safe, build customer relations and preserve reputation.
But mandatory training often gets a bad rap, and frequently deserves it. Compliance is the “dull but necessary” stuff. That makes it difficult to achieve learner engagement. It can be hard to keep up with changing regulation. Necessary repetition makes it boring. And too often, the training doesn’t have any impact anyway. These barriers drive a tendency for compliance training to be reduced to a box ticking exercise – a conspiracy between business and learner – “let’s just get this out of the way, then we can get on with the real work”.
Given these challenges it’s worth thinking about what compliance training seeks to achieve, and whether ‘training’ is really what’s needed at all. Think about compliance issues in your organisation. Do problems arise because people haven’t learnt what they should do? Or do they arise where people don’t do what they should – even when they do know what the right thing is?
For many businesses, the latter case is more prevalent and problematic – we know what we should do, we just don’t do it. And that doesn’t imply willful malpractice. It says more about people in a hurry, the attraction of established shortcuts, following received wisdom and an innate human tendency towards over-confidence. We all know what that’s like – who hasn’t ridden a bicycle without a crash helmet, written down their password, or left that spill to clear up later, even when we know these probably aren’t the best or safest choices?
What we do in private is up to us, but in many workplaces simple conduct choices have significant and serious consequences. For a stark ‘non-compliance’ story consider the widely publicised failure of care at the Mid-Staffordshire NHS Foundation Trust of 2005-2009, which ultimately resulted in unacceptably high rates of patient mortality. Subsequent enquiries revealed that many serious breaches of good practice were committed by experienced care professionals who had received lots of compliance training and ‘knew’ what they should do. So why didn’t they do it?
At Acteon we talk about ‘competent compliance’, and to achieve that we don’t just need people to know what they should do. We need them do it at the right time, and do that consistently. And ideally, we’d like it if they felt positive about doing the right things, and understood how it leads to better outcomes for themselves and others. To achieve that, we think that in addition to, or instead of, training people, perhaps what we really need to do is give them a nudge in the right direction.
I mean ‘nudge’ in the sense that’s used in behavioural science to describe how providing simple, positive, timely and socially meaningful prompts can help people make better choices of action. The idea is crystallised and exemplified in the book “Nudge” by the American academics Cass Sunstein and Richard Thaler. They describe how careful thought about process design and presentation of information can provide effective ‘nudges’ to positive action in a huge range of scenarios from completing tax returns, to reducing litter, to keeping urinals cleaner!
Let’s take a very simple ‘compliance’ example from outside the workplace – adherence to motoring speed limits. Most drivers have ‘learnt’ about why speed limits are necessary, and which limits apply in which situations. Yet large numbers of drivers don’t adhere to them. So authorities try many approaches (or nudges) to change behaviour – TV adverts, speeding fines, awareness courses and speed cameras are all familiar examples. It turns out that one of the most effective nudges is also one of the simplest, and you will have experienced it. Using electronic signs to show drivers a smiling face when they are within the speed limit, and an unhappy face when they are exceeding it, proves significantly more effective than using speed cameras to achieve compliance with speed limits. Why? Because it’s a simple, clear and socially relevant prompt delivered at exactly the right time.
These key characteristics have been found to be the essence of effective nudges to behavioural change – processes and messages that are easy, attractive, timely and social.
So what is the relevance of nudges to compliance training in the workplace? You may not be able to strategically position signs with smiley faces, or re-engineer processes to suit, but you can design your compliance ‘training’ for simplicity, attractiveness, timeliness and social relevance. The result may not look quite like the box-ticking stereotype of mandatory training, but the chances are it will be more effective at achieving the behaviour change you want.
This approach underpinned the success of Acteon’s work with Channel 4, to help the UK broadcaster ensure that colleagues were living up to the standards of professional behaviour set out in its Code of Conduct. The Code covers all sorts of behaviour, from information security to managing your expenses, and the content falls well within that “dull but necessary” category that defines so much mandatory training.
Rather than focus on the wide range of detailed policy and procedure that underpins the Code of Conduct, we designed a programme that focused on promoting a single key behaviour – building the habit of checking your professional conduct and asking yourself “Is it OK?” This simple core message is made attractive and memorable by linking to the hit Channel 4 programme “The Last Leg” which also uses an “Is it OK?” question feature. To help reinforce behaviour change, the programme was delivered as a six week ‘campaign’ using a range of communication and learning channels including e-learning, video, intranet, email and electronic message boards. The campaign helped provide timely reinforcement and ensures messages endure outside of the training environment.
We built social relevance by linking the importance of professional conduct to preserving the brand values that Channel 4 colleagues care about. And the programme emphasises the impact of personal conduct on friends and colleagues at work. Rather than regurgitate lots of policy and procedural details (that learners can’t be expected to remember anyway), the programme signposts colleagues to the relevant materials they need to be aware of when completing specific actions.
This focus on simple, attractive, timely and socially relevant messages proved a powerful ‘nudge’ to drive engagement and behaviour change, and resulted in Channel 4 exceeding all its expectations from this ‘training’ intervention. The programme won 3 E-learning Awards, and led Channel 4 CEO David Abraham to say “The “is it OK?” theme was one that resonated with our staff and was an innovative way to give ownership back to our people. The results have been tangible.”
At Acteon, we’re using this approach to help build competent compliance for clients as diverse as care home operators and national supermarket chains. We’re working with them to re-invent their compliance training interventions from “dull but necessary” chores into meaningful prompts to positive behaviour change. This approach doesn’t ignore the fact that in many cases competence is underpinned by core knowledge that can be effectively delivered through conventional training. But it recognises that for consistent positive behaviour change we need to do more than that – and a nudge in the right direction can make a big difference.
