Are you more likely to order the Dolphin Fish or Mahi Mahi from a restaurant? How about a Sea Bass instead of Black Seaperch? Surprise – they’re exactly the same thing. I’ve previously written about innovative names that companies are using to try to make compliance elements more palatable for their employees, and of innovations that highlight key elements of the program. I just got back from the European Compliance Week conference, where I heard some interesting and exciting ideas about naming and re-framing compliance terms. Why not try some of these out?
Change “Training” to…
It has been said that animals are trained, but humans are educated. The word “training” can conjure visions of being in an elementary school classroom. One company has taken this seriously and changed the name of its training sessions to “engagement sessions.” The word “engagement” creates an expectation of personal involvement, instead of being lectured to. The name can be especially good for live training sessions that, hopefully, are engaging.
Another company calls their specialist manager and gatekeeper training “commitment sessions.” This connotation sets the expectation that the involvement of the managers won’t simply be to listen to the compliance officer, but to show up to actively commit to the compliance program and ethics at the company.
Listening Up, Not Just Speaking Up
One compliance officer at the conference said that she realized that speaking up was just one-half of the equation. In order for there to be balance, there needs to be someone speaking and someone listening. The company embarked on a training program (whoops! engagement program) to help managers and compliance ambassadors learn how to listen more effectively. The sessions helped people learn how to actively listen, be empathetic, learn how to report to compliance, and how to ask open-ended questions in order to get as much information as possible from someone with a concern.
Not only is this type of engagement great for culture improvement, it also allows the company to prove that it has trained its managers/gatekeepers on when and how to report misconduct. This conforms with the new DOJ compliance program evaluation guidance, where prosecutors are instructed to ask “gatekeepers” whether they know what to look for with respect to compliance failures, and how to report concerns.
Speaking up is critical, but someone needs to be listening when whistle-blowers do it. Study after study confirms that most employees report concerns to their manager instead of to the speak-up line. By enabling better responses to these concerns, the company benefits both the person complaining and the one hearing the complaint.
Data Protection Officer as…Chief of What?
At the conference, one European Data Protection Authority’s representative suggested that we change the name of data privacy officers to “Chief Citizen Officer.” He believes that tension occurs when a company desires to exploit the data of its customers in unreasonable ways. Instead of considering people “customers,” his viewpoint was that the Data Protection Officer’s job was to protect people as citizens or individuals in the world. He believes that the change in connotation from “Data Protection Officer” to “Chief Citizen Officer” would help companies to do the right thing when it comes to data. I don’t think “Chief Citizen Officer” is likely to catch on, but it is an interesting change of mindset with respect to the role of DPO.
Compliance programs continue to evolve and get more creative all the time. By taking the time to either re-name or re-frame the conversation within your company, you can create more engagement and interest in the program. Besides, your employees would much rather have Shrimp Scampi than Langoustines in Garlic.