Regulating Informal Learning

In regulated, compliance-driven industries, informal learning can be a dicey proposition.

By Margery Weinstein

No organization today wants to be seen by employees as controlling or limiting. But companies in industries such as banking and health care must balance employees’ desire for informal learning with the need to comply with federal and state rules and regulations. With confidential information at risk and outside laws guiding the company’s behavior, problems could arise if employees are left to their own devices. Fortunately, many of these organizations have been able to strike a balance between freedom to learn on employees’ own terms and the need to protect company—and customer—business.

Mapping Out “Informal”

Learning and development at TD Bank’s TD University embraces a 70/20/10 model for successful learning experiences, says Senior Vice President and Head of TD University Brian Sullivan. “We believe that adults learn best with a 70 percent focus on actual job or community experiences, a 20 percent focus on people relationships, and a 10 percent focus on formal learning.”

One example of this approach is the company’s development of Leadership Learning Maps, which are available to all TD Bank employees. “We model and align each Learning Map to our company’s own Leadership Principles. Each map contains specific opportunities related to on-the-job experiences (i.e., special projects, stretch assignments, and people development opportunities) and relationship management (i.e., mentor and mentee opportunities), coupled with specific TD University training course recommendations and professional reading resources, available at no cost to TD employees.”

TD Bank also utilizes this balanced approach in its ACHIEVE program for retail banking employees. The program is designed for high performers to prepare themselves for their next role. The program relies heavily on job experience and the people relationship aspects of the company’s learning model. “Job experiences are rich and specific, including such things as conducting business calls and running meetings,” says Sullivan. “We also leverage sponsorship and mentoring. Our participants utilize a ‘rewind’ process to discuss with their mentors what they’ve learned and how they’ve applied it. To ensure program participants are proficient with their formal and informal learning, each participant presents to senior-level management prior to graduation.”

A Better Blend

For some organizations that are heavily regulated, informal learning options are part of a larger learning blend. “Our organization views informal learning as a natural opportunity to provide relevant, timely, and learner-centered learning convenient to the workspace,” says Diane Sargeant, director, Organizational Learning and Development, and Tammy Newcomer, manager, Learning Operations and Innovation, WellSpan Health. “It is another way we can ‘blend’ our learning design to mesh well with our formal learning programs as the informal leaning provides added value to the learners. We view learning as not occurring just in the classroom, but also in the operating and exam rooms, boardrooms, the learner’s computer, and his or her tablet.”

Sargeant and Newcomer explain that instructional design principles are incorporated to organize content and promote dialog within the various learning methodologies. The informal learning focus keeps it relaxed for learners so they can learn in various ways.

“A difference from formal learning is that we do not track ‘completion’ of this learning, but rather provide various options for learners to connect to promote employee development,” they point out. “We focus on ‘gathering people’ in various methods, such as online with blogs, an intranet site that allows discussion and feedback, as well as posting various associated resources to ‘explore more.’” An example of this is the company’s bi-annual leadership forum in which C-suite executives facilitate discussion about books and current leadership topics.

Informal Learning for Reinforcement

At NewYork-Presbyterian Hospital, informal learning often is used as a way to back up more structured programs. “Regulatory requirements are met with formal learning, but informal learning may be used as reinforcement,” says Vice President and Chief Learning Officer Carol Silk. For example, training on fire safety is provided formally upon hire and annually to meet regulatory requirements. In addition, NYP also utilizes its Patient Safety Fridays (PSF) program to ascertain staff knowledge level through staff interview questions. “The PSF interview occurs each week, and data is collected on topics such as knowledge of Fire Safety protocol,” says Silk. “This closed-loop model, through PSF interviews, helps ascertain staff knowledge level as a result of formal and informal learning.”

Meanwhile, confidential information—regardless of how informal the learning—remains confidential. “All NYP employees receive training upon hire and annually regarding the use of confidential information,” says Silk. “Proper use is considered an expectation of employment for all employees and is part of NYP’s Code of Conduct. Therefore, all employees know they must use fictitious or test data as part of any training examples. Formal and informal training materials are housed on a secure intranet or via team sites.”

Self-Directed Learning

ESL Federal Credit Union does not employ the use of informal learning to meet compliance training requirements in the organization, but that doesn’t mean informal learning doesn’t happen. “As a federal credit union regulated by the National Credit Union Administration (NCUA), we must use formal compliance e-learning modules with the most current content, formal assessments (tests), and completion requirements for each role in the company,” say Training Manager Kelli Loveless and instructional designer Jim Darby. “Though informal learning and knowledge sharing may take place in the completion of these modules, we adhere to the requirements established by the NCUA.”

Loveless and Darby say their Learning and Development team tries to provide employees with as many resources as possible to learn. For example, ESL employs a multifaceted approach to promote social learning. In February 2012, the Learning and Development team launched an all-new interactive e-zine on the organization’s intranet, which is the primary communication and knowledge management resource for the company’s 600-plus employees. “Employees often review this learning e-zine in team/staff meetings to encourage discussion, teamwork, and creativity from a sales or operations perspective,” Loveless and Darby explain. “They also work together to complete online scavenger hunts included in each issue. The e-zine publication contains feedback channels in which readers can submit questions, best practices, and insights that will benefit others in the company. The feedback channels, which are monitored by the Learning and Development team, behave much like an asynchronous discussion board. Learning and Development culls reader postings and determines which ones to showcase in future e-zine editions.”

Another informal learning program at ESL is the professional learning and development program, iVisit. “The name, ‘iVisit,’ reflects its connection to our Learning and Development portal (iLearn) and symbolizes the interactive nature of this professional learning and development activity. The program aims to: help increase understanding, knowledge, and communication between employees; foster organizational teamwork that enables ESL to better serve members and one another; and enable employees to pursue career and educational interests,” say Loveless and Darby. “Ultimately, iVisit aims to improve our organizational communication, teamwork, and service to one another—as well as our members.”

More Than One Way to Learn

In addition to compliance-specific training, Edward Jones uses field supervision to make sure branch teams receive the training they need to meet compliance requirements. “Field supervision directors are responsible for helping to ensure branches meet compliance requirements, so they take every opportunity when responding to requests and questions to educate through one-on-one conversations,” says Director of Learning and Development Caryn Staebler. “They even attend regional meetings for financial advisors so the financial advisors get to know them and can ask questions. A financial advisor in each region serves as the Compliance Information Leader, participates in conference calls to discuss compliance issues, and then has conversations with or holds presentations for branch teams in their region. Informal learning is passed along that chain, from the compliance expert to volunteer leader to the branch team.”

To encourage associates to innovate client-service improvements, the firm introduced the n.e.w. Innovation Program (iNnovate to drive Excellence to Wow clients) in October 2010, says Department Leader in Client Service Excellence Kirsten Wheeler. “This online community combines innovation training, client-service collaboration, and recognition to build our competitive advantage in the financial industry,” she explains. “Because we are in the highly regulated financial industry, all n.e.w. posts must be screened by our compliance division, a process accomplished within 24 to 48 hours. But this has not discouraged participation. More than 20,000 associates visit the online community every year, submitting thousands of ideas and suggesting innovations that we implement.”

QUICK TIPS

  • Create individualized learning “maps” for employees so that after they complete the more structured, compliance-driven training, they have flexibility in learning options.
  • Make the informal component part of a larger “blended” learning approach by breaking down by percentage how much of the training must be compliance driven, how much classroom driven and online, and how much informal.
  • Teach the lessons that must be mastered to meet compliance requirements in a structured setting and then use informal lessons such as collaborative learning or social learning to reinforce the lessons.
  • Use supervisors in the field or in each department to bring compliance lessons to life by underscoring on-the-job teachable moments.
  • Consider self-directed learning in which each individual can learn required material in the format he or she likes best, but all employees take the same assessment test to prove they mastered compliance-related lessons.
  • Offer opportunities for creativity in idea generation. Tap your workforce to submit their best ideas—even if those ideas must be reviewed by the C-suite to ensure compliance concerns were not violated. Most employees will still be excited to contribute.
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