The financial services industry is governed by the Financial Services Authority (FSA) Data Protection (DP) Policy. Organizations have to demonstrate at all times the strict application of controls and high standards in regulation with the Data Protection Act. As an organization we have to promote high standards within the company of dealing with personal information, whether it is customer or employee information. The importance of DP ensures that compliance training is of paramount importance during the induction of new recruits, refresher training and management awareness.
As an organization we were faced with the problem of delivering DP legislative compliance training that employees retain and managers reinforce through their language, actions and behaviours. Historically, within our organization legislative compliance training, whether it is health and safety or data protection is notoriously difficult to deliver. It results in difficulties for the trainer in ensuring the training delivery contains the right mix between a general awareness of the principles and the employees understanding the fundamental importance of legislative compliance from both a customers’ and an organization viewpoint. As trainers you often feel you are delivering the sessions to ensure compliance as opposed to ensuring staff understand and value the overall importance of the message.
The DP training was completed using a DVD and, although effective and informative, as an organization we had reservations about relying solely on one training method. This reliance did not allow the trainers to apply alternative learning methods, or check full understanding of the subject matter, nor did it allow initial and continuous assessment to verify competence. The training video was historically delivered at the end of induction training and it was evident that the learning style adopted conflicted with the rest of induction, which was interactive and varied in style and delivery.
The decision was made to fully apply the principles of training and development to DP compliance training. The objective of this was to enhance the employee’s knowledge of DP but also reduce significantly the organization’s potential risk of an employee’s failure to comply with Financial Services Authority DP Policy. Without the knowledge of how DP governs employees’ roles at Debt Free Direct there could be cause for customer complaint. This can affect the company’s reputation and even result in the possibility of court action.
The training team embarked on a group problem solving exercise to design a training course that utilized learning theory to increase the effectiveness of the training and the retention of DP knowledge by the call centre staff. The outcome of the problem solving exercise is detailed below.
Training methods introduced
The first decision was to introduce different training methods to increase the delegates’ ability to retain information. It was decided to include group activities, lectures and individual activities to reinforce the effectiveness of the training. This would be delivered across varied and productive training methods:
- learning maps;
- an activity;
- a mini-lecture;
- imagery.
Understanding the chosen training methods
Learning maps
A stakeholder approach from three different viewpoints (customer, employee and organization) was utilized in the learning maps exercise. The learning maps give the delegates the ability to understand the concept of DP and how it can affect them, customers and the organization. This also gives them the ability to take the learning maps away with them and reflect on these at a later stage, aiding several learning styles. This will ensure that a greater percentage of individuals can benefit from this method of training.
The delegate will be given three sentences:
- How does data protection affect me?
- How does data protection affect the customer?
- How does data protection affect the organization?
To this they must create learning maps in pairs about their thoughts on DP within the workplace. This can be based on past experience from previous DP training they may have had at other companies and from their general understanding after watching the DVD. They can draw or write their thoughts on the mind map.
Activity
An activity was introduced to ensure reflection on the key messages of the DVD. The objective of this was to introduce the information they have learnt in a fun and interactive environment. This also enabled the delegates to test their knowledge and understanding of DP and relate this information to their daily roles within the company as well as help them understand the importance of DP. It also enabled the trainer to gain an understanding of the delegates’ knowledge of DP and give the opportunity to rectify any areas that may have been wrongly interpreted by the delegates.
The delegates are split into two groups:
- Using the data protection module and their knowledge previously gained the delegates write 15 questions (with answers) to ask the opposing group.
- Group 1 will then ask Group 2 their first question
- If Group 1 get the question wrong they must remove a piece from the Jenga tower; if they answer correctly, Group 2 then have to remove a piece from the Jenga tower.
Note: each group must have one spokesperson that can answer and ask the questions.
They have 30 seconds to answer the question; otherwise they must remove a piece of Jenga. The team that wins are the ones that do not knock the Jenga tower over.
The trainer will play the role of the referee, ensuring that only 30 seconds is given for the team to answer the question and the rules of Jenga are followed. The referee’s say is final.
Mini-lecture
This is used to reiterate the set learning points that these individuals have gained and learnt during their training session. This section was completed as a summary, ensuring the delegates understand the main objectives. The trainer will also be able to confirm any information that they may still be a little unsure about.
There are certain main points that must be covered in the mini-lecture to ensure that all the main objectives and aspects of DP have been covered during the training. These must be reiterated to the group by the trainer and reference can be made to the DP module that they will be given. Within the module, there will be space for the delegates to make additional notes to aid them with future reference and understanding.
The main aspects that must be covered by the trainer during the mini-lecture are:
- What is the Data Protection Act all about?
- Ensure all delegates understand the terminology used in DP.
- What is a Data Subject?
- What are their rights?
- Why should Debt Free Direct (DFD) comply?
- What happens if DFD doesn’t comply?
- How does this affect you?
- DFD’s DP protection policy.
- The eight principles of DP and how they affect you as employees.
Imagery
This is used to aid the delegates by constantly refreshing their memory of the eight main principles of DP. It was proposed to include further imagery in the training by adding peripherals to the room and to shared work areas.
It is difficult to remember all eight principles of the Data Protection Act and how they affect employees at DFD. To aid their retention of this knowledge peripherals will be placed around the room. These will consist of the mind maps they created to remind them of their initial thoughts of Data Protection and laminated peripherals will also be visible and used when learning the eight principles of the Data Protection Act, using characters to relate to the eight principles will do this.
As we all know, Snow White plus the seven dwarves equals eight characters. Each character will represent one of the principles. The posters will be placed around the room. They will each have a picture of the character, one of the principles, and how that principle affects the individual at work, eg:
- Dopey – Principle 4.
- Personal Data Must Be Accurate.
- What does that mean at DFD?
- You must ensure all data are accurate when first recorded.
- You must make sure that if an inaccuracy comes to light it is corrected at once.
- You must update the information when necessary.
Ongoing evaluation has identified that with the added training methods appealing to all four learning styles the retention and understanding of DP increased dramatically.
A further decision was made to roll out the same course to team leaders to ensure a full refreshment of team leader knowledge of DP.
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