Privacy Awareness

Using eLearning to raise staff awareness of privacy European-wide

But why choose web-based training over the more traditional classroom-based awareness programs?

The traditional method has a certain inflexibility and dullness about it," explains Trower. "So we thought that a web-based course could be designed to be quite interactive and user-friendly, engender some interest, while at the same time be very flexible, in that people could do the course at their own leisure and new people, as part of their induction program, could also do the course."

One of the advantages of web-based training, he says, is that it is much more visually stimulating than traditional training methods, where lawyers or consultants tend to come in and run through a slide show of data protection principles. Programs using graphics and animation avoid the boredom factor while interactive elements that get staff to answer multiple choice questions or complete quizzes help to reinforce key privacy messages. Add to that mix the flexibility of a package that can be used anytime, anywhere and you have a program that is ideal for large organizations trying to reach out to thousands of staff.

Setting up the project

IMS's work on the project started at the end of 2002 with the plan to roll out the course to around 2,000 staff across seven European countries: the UK, France, Belgium, the Netherlands, Germany, Spain and Italy. To help manage the process, Trower appointed a project manager from the IMS legal team, as well as setting up a steering group comprising of representatives from IT, HR, legal and internal communications. Following an initial project meeting with the steering group, SAI Global researched the technical issues with IMS's IT team and then produced a scoping document setting out the key content, technical, phasing and roll-out requirements.

Owing to the demanding roll-out timescales, detailed project planning and rigorous management were essential to ensure timely input from all parties and efficient development. SAI Global therefore developed a detailed project plan which, following agreement with IMS, formed the basis for management of the project. The IMS and SAI Global project managers liaised closely throughout to agree ongoing minor adjustments to ensure that the flow of the project remained on track.

As the course was targeted at all staff from all levels across the organization, the issue of where to pitch the content became a significant dilemma, he explains. Do you keep the course simple and straightforward, or do you include plenty of high level detail? "Ideally you want it at two levels," he explains, "with basic information for everyone, and then more detailed messages for key people, whether they be in security, marketing, or HR."

Customising content

In developing the program, IMS chose to partner with SAI Global, a provider of interactive web-based training program. One of the reasons for choosing the SAI Global course, says Trower, was because it allowed them to adjust and tailor the content to make it more relevant to their staff. "We took the program and customized it for our own company," he explains. "So we looked at the particular issues that are relevant to us, whether it be market research, the anonymization issues that we have, or data transfers."

Flexibility was also required to roll out the course across different countries. Aside from the obvious language differences, the content of the training package had to be adapted to reflect variations in national laws. Trower explains that they started off with a master version of the course for the UK, and then used in-house counsel and external lawyers to adapt the master copy to address local variations such as response times to subject access requests, or definitions of data protection terminology such as what is personal data or what is a ˜data controller/processor. They also tailored the enforcement section of the course to add on country-specific examples of privacy breaches.

Once the legal side was completed, SAI Global then arranged for the content to be professionally translated into the correct languages. Following approval of each script by IMS, SAI Global then programmed each language version and carried out a thorough quality assurance process. The language versions were developed in series to co-ordinate with availability of IMS resources and allow SAI Global to keep the same programming team working continuously on this project, producing each version in turn.

Rolling out the program

In delivering the course to staff, says Trower, input from the internal communications team was vital. "Clearly, one of the most important things was the communication about the rollout of the course, because you can't just dump it on peoples laptops." The process involved a communication from the European President at IMS to reinforce the importance of the program, in addition to keeping departmental line managers in the loop and explaining to them how the program would be run.

In each country, the database in the SAI Global learning management system was pre-populated with the relevant data for the target audience from their HR database. This enabled the roll-out to be managed and user progress and performance to be tracked and reported on.

Before launching the course to staff, they also carried out a final testing stage in each country. "We tested it on a few guinea pigs, both to see whether they could follow the course in terms of the content  whether it was too hard and also in terms of whether the software was working."

Assessing the results

One of benefits of most web-based training programs is that they enable companies to gain greater feedback into whether it has worked. Management reporting tools help the administrators to not only find out who has done the course, but how well they performed.

Trower stresses that although IMS monitored staff performance, the course was not designed to catch people out. There were no disciplinary procedures for failing the course, he explains. "It's simply an interactive and cooperative process. If we find that people keep failing, we’ll go back and provide assistance and additional support."

Aside from one or two minor technical glitches, Trower says the course went extremely well, with an excellent response from employees. "I haven't had any negative feedback at all. People have said they found the course really interactive."

He has also seen a noticeable difference in staff awareness. "You can see the results when you speak to people who come for advice," he says. "They're clearly much more educated since they've done the course. I think it's been a real success."

Overall Trower says the web-based training approach is both a flexible and effective way to raise staff awareness. But, he warns that companies thinking of adopting similar programs should bear in mind that things can often take longer than you expect. IMS set itself an ambitious timeframe, rolling out the program on a consecutive country-by-country basis in under a year. "I think that if we were to do it again," he says, "we would do it slower. You have to be realistic about the amount of time you give to it. Because it is quite a complex process in terms of the number of countries dealing with difficult issues, and the complexity on the IT side."