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Online Compliance Training
Colleagues, Agents, Operators and their Assistants
Overview
Post Office Ltd operates in an ever changing environment in relation to the compliance that must be delivered and
adhered to for a wide range of products and services that we transact within our branch network. As such, it is vital
that Post Office Ltd provides the necessary training, support, advice and assurance to the people working in all
branches to ensure they are fully equipped to operate compliantly. The result is customers are provided with the
best possible service, our reputational branch is protected and the regulatory risks are minimised.
In this ever-changing regulatory environment, Post Office Ltd must ensure it identifies, manages and controls any
existing and future regulatory risks.
Post Office Ltd’s current approach for administering Compliance Training, a combination of workbooks supported by
a test on Horizon for branch colleagues, a manual class room process for new joiners and the HR system known as
‘Orbit’ for all other colleagues, is a reactive and inflexible process that requires refreshing to ensure the business
continues to effectively and efficiently delivers on its obligations. It is an approach that confirms adherence to a
process rather than one which supports engagement and true understanding and deployment of the training.
Our current process for testing knowledge and understanding of compliance is fragmented and does not meet the
changing needs of the network models. It is also the process that is being favoured by Product Teams to
demonstrate to Clients such as DVLA compliance to training and procedures and there is a risk that the approach will
overload the branch network.
The aim of this paper is to propose a proactive rather than a monitoring approach to regulation, via a digital multi-
channel solution, which is becoming a full-time strategic business activity for many organisations.
Background
Everybody who works in a branch is required to understand each compliance module and complete the associated
test before they start serving customers.
Post Office Ltd’s compliance training modules cover a number of different regulatory areas and help branch
colleagues understand what they need to do to ensure that the business operates in a compliant way. This helps to
ensure our customers know that they can trust the Post Office brand.
There are 3 main approaches to deliver Compliance Training —
e New Joiners
New joiners to crown branches and new agents and operators attend classroom induction training sessions and will
complete the tests while they are in the classroom. Compliance workbooks are read and a manual test is completed
and marked by the Field Support Advisors running the training. The joiner must then complete the test on Horizon
once assigned a branch to obtain a receipt of completion for each of the compliance modules.
For agency branches, including those operated by multiple partners such as McColls, it is the responsibility of the
agent or operator to recruit their own members of staff and ensuring that they read the workbooks, complete the
tests on Horizon and obtain a receipt of completion for each of the compliance modules before they start work. For
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some of the Network Transformation branches, a proportion of the assistants will be offered places on the
classroom induction training sessions.
* Existing Branch Colleagues
Historically, Post Office has had an obligation to demonstrate to the different regulators that all branches have been
trained regarding how to operate compliantly. This has led to the approach of deploying an annual training plan
which requires all existing branch colleagues to read the relevant compliance workbooks, complete the tests on
Horizon and obtain a receipt of completion for each of the compliance modules, in order to transact the appropriate
products and services.
The modules are refreshed on an annual basis and are issued to the branch network at intervals during the year.
Each module is accompanied by a 10 question Horizon test, which must be completed within a three week period. A
printout from the Horizon system is then produced which identifies the user ID of the person who has completed the
test and this also indicates they have passed the test.
The colleague in the branch must select what role they play in the branch — Agent, Operator, Branch Manager,
Officer in Charge or Clerk.
« Head Office & Central Support Teams
As directed by Post Office Ltd, usually to support Christmas pressure or industrial action, head office and central
support teams access the HR ‘Orbit’ system to read the online compliance modules and take the associated tests,
which must be completed prior to working on the branch counter.
The modules are refreshed on an annual basis and are implemented onto the HR ‘Orbit’ system network at intervals
during the year. Each module is accompanied by a 10 question test, which must be completed prior to working on
the branch counter.
In addition, there are some compliance modules which are unrelated to branches, which all central support and
head office teams must complete annually, e.g. Data Protection/Information Security. These are available on the HR
Orbit system. New joiners are asked to complete this as part of their induction and this is monitored by HR.
Existing Compliance Management
Historically, it has been the role of the Compliance Team, Branch Standards and the Network Engagement Team to
determine the annual compliance training plan. The Compliance Team provide the guidance on what training needs
to take place to satisfy the regulators. As a group, they decide on the timing of the different modules that best suit
the needs of the regulator and the branches and sign off the content of the training. For example, mail compliance
training is typically deployed in October to ensure that branches are re-trained at the point proceeding the busiest
time of the year for mails transactions.
The Branch Standards Team is responsible for ensuring that all branches complete the training within the required
period. They are not responsible for ensuring that Head Office and Central Support Teams complete the training.
If a different team want to add to the compliance training plan then the request will be raised via the normal
business change process (Gating).
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Existing Compliance Auditing
The Field Support Team are responsible for ensuring that new colleagues, agent, operators and any assistants
attending the classroom complete the relevant compliance training. They provide workbooks to the new entrants
mark the tests and input the results to a sharepoint site.
The Branch Standards Team is responsible for ensuring all branches complete the required on-going training to the
required timescale. However, the monitoring approach varies depending on the type of branch.
® Crown branches. Branch managers are requested to complete a sharepoint site to indicate how many members
of staff are working in the branch. A daily Horizon test file is polled by the Compliance Team and sent to the
Branch Standards Data Team and this information is then used to check the number of different users which
have completed the training. A branch isn’t classed as fully compliant until the expected number of users have
completed and passed the training. Regular reports are sent to the Crown management team to inform them
who has completed the training and they also assist in ensuring the branches complete it on time.
e WHSmith branches. These branches are treated very similarly to Crown branches. Staffing information is
provided to the Branch Standards Team by the WHSmith relationship team and the Branch Standards Team track
completion against the number of staff that are expected to complete the training.
* Agency branches. As above, the data of test information is polled daily and sent to the Branch Standards Data
Team for analysis. Whilst the report indicates the different users in the branch who have completed the training,
because the data regarding the assistants who work in our branches is not 100% accurate and due to the fact
that the agent or operator is contractually responsible for ensuring all staff have been trained, the branch is
classed as compliant if there is a user ID who completes the training at the agent/operator/officer in charge
level. Reminders to complete the training are sent to branches throughout the training window. The Branch
Standards Team also make pro-active calls to branches who have yet to complete the training before the
deadline. They also manage the process for agency branches where they have failed to complete the training on
time and initiate the relevant corrective action. If an agency branch fails to complete the training on time then
this could result in a visit by a Field Support Advisor and the agent will be charged up to £100 to cover the costs.
An example follow up process has been embedded.
Reg Comp
FU-Shaded.vsd
Completion of the relevant compliance training modules also forms part of the branch Compliance audit. The Field
Support Team identify which modules should have been completed, identify the members of staff working in the
branch and check that an Horizon receipt is available for all members of staff to ensure that it has been completed.
In 2012/13, the Field Support Advisors carried out approximately 2800 compliance audits across the branch network.
Whilst Head Office and Central Support Teams are required to undertake the training via the HR Orbit system, there
is no co-ordinated central monitoring that takes place for completion.
The Civil Aviation Authority also has the legal right to audit any of our branch network to ensure that any colleague
handling mail in branch has completed the Dangerous Goods training. They also have the right to request training
record information at any time.
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Risks & Issue with Current Process
e Three separate methods for completing and managing the training results in lack of join up between the teams,
lack of clarity of ownership and three sets of training data and information being held in different places. This
leads to inefficient use of resource, makes it difficult for Post Office to understand the true picture of compliance
which in turn puts Post Office at risk if audited by the likes of the Civil Aviation Authority.
@ The lack of an alternative on-line channel to complete the training wastes time and resource in the induction
training for new entrants and also makes it operationally difficult for branches to complete on Horizon,
especially in the new Local model. All assistants within the Local model are required to undertake certain
compliance training modules. In some instances this could be 25 people who need to access one piece of
Horizon equipment. Customers cannot be served whilst the training is being completed, which can also
encourage the behaviour of doing the test to get it over with, rather than to really understand the content of the
training. This doesn’t create an ideal training environment if colleagues are not given adequate opportunity to
digest the training.
The lack of an on-line channel also makes it difficult for temporary agents and operators or holiday reliefs to
access training information and keep records. They are often unaware of which modules need to be completed.
The conscientious ones will undertake the training in all branches but there is also the risk that a large number
will be working in branches without having the correct awareness.
* The Horizon method of training restricts the type of questions that can be asked due to the fact that the fields
are limited and questions one and ten have to either be a “yes/no” or “true/false” answer. This often leads to
simple questions being asked which does not really test true understanding or deployment. Feedback from
branches indicates that they can often complete the test without having read the training book and therefore
compliance training is often seen as a tick-box, non-value add requirement and something that they don’t
engage with.
¢ The Horizon method also restricts what and when compliance training is delivered. The timescales needed for
change mean that quick, random tests of knowledge within the network cannot be undertaken.
e The Horizon method also means that every type of branch has to go through the same training. There is no
flexibility to train and test understanding depending on the size, customer traffic or risk profile of the branch. It
also doesn’t facilitate more frequent, varied testing of branches where there is a known risk.
*® The current management process of the training is resource-hungry and in-efficient.
* The lack of quality data regarding who is working in our branches makes it difficult to manage the process.
e@ The content of the training does not vary that much on an annual basis yet the work-books are still printed and
sent to each branch. The workbooks are often very large in size, often being more than 20 pages. This also
exacerbates the situation that colleagues don’t actually read the training before doing the test. Confirmation for
agents, operators, branch managers and Officers in Charge that everyone has completed the training involves
manually checking receipts in branch.
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Costs to Administer Current Process
Costs shown in the table below have been provided by Georgina Blair, based on 2013/14 requirements.
* Additional Cost Areas (need to understand these costs / effort if available)
Lee Heil’s team incur postage and time in packaging up the workbooks, and the training team incur cost in marking
them and sending in the results. Operators’ and agents’ assistants do the test in branch on Horizon, and in a newly
opening branch that takes up a lot of the trainer’s time.
There are also the management costs per module. The Branch Standards Team can make approximately 1000 phone
calls per training module. Management time is also needed to feed into the training content, process the
management information, up-load the call information, analyse the data and then initiate any corrective action
process.
Date of Invoice I Company Description Who does spend Amount
benefit (ex vat)
April 2013 Crystal Keeping online DP module open until May 17 New joiners 303
April 2013 Comms Branch Focus articles (2) re Data Protection module Branches 1482
(internal)
June 2013 Linney Dangerous Goods 2 (Domestic) - workbook v.1 & v.2 Branches 6224
June 2013 Linney Dangerous Goods 2 (Domestic) - online quiz Central functions I 1865
June 2013 Skills group I Two days of test analyst time to test Horizon DG2 test Branches 1000
(internal)
July 2013 Linney Reprints - DG1 workbook - 1000 v2 for new joiners New joiners 1453
July 2013 Linney Reprints - Telephony workbook - 1000 v2 for new joiners New joiners 956
July 2013 Comms Branch Focus insert to update Financial Services workbook Branches 1482
(internal)
August 2013 Linney AML & Info Security - workbook v.1 & v.2 Branches 8760
August 2013 Skills group. Two days of test analyst time to test Horizon AML/InfoSec Horizon 1000
(internal) test
‘August 2013 Linney AML & InfoSec - online module & quiz Central functions I 4714
October 2013 Linney Reprints - FS workbook - 1000 v.2 for new joiners New joiners 946
October 2013 Linney Reprints - DP workbook - 1000 v.2 for new joiners New joiners 1543
October 2013 I Linney Reprints - DG2 (Domestic) workbook - 1000 v.2 for new New joiners 1894
joiners
October 2013 Linney Reprints - DG1 (International) workbook - 1000 v.2 for new New joiners 1543
joiners
November Linney Mails workbook - v.1 & v.2 New joiners 4025
2013
November Linney Mails - online module and quiz Online 4090
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2013
November Skills group I Two days of test analyst time to test Horizon Mails test Branches 1000
2013 (internal)
December 2013 I Linney Reprints - Homephone & Broadband - 1000 v.2 for new New joiners 1200
joiners
January 2013 Linney Locals Foundation Module - 1000 for new joiners New joiners 3000
January 2013 Linney Financial Services workbook - v.1 & v.2 Branches 6250
January 2013 Linney Financial Services - online quiz & test Central functions I 4500
February 2013 I Linney Homephone & Broadband workbook - v.1 & v.2 Branches 6250
February 2013 I Linney Homephone & Broadband workbook - online quiz & test. Central functions I 4500
February 2013 I Skills group I Two days of test analyst time to test Horizon Homephone & I Branches 1000
(internal) BB test
March 2013 Linney Data Protection workbook - v.1 & v.2 Branches 6250
March 2013 Linney Data Protection workbook - online quiz & test Central functions I 4500
March 2013 Skills group. Two days of test analyst time to test Horizon Data Protection I Horizon 1000
(internal) test
March 2013 Comms Branch Focus articles - estimate Comms 10000
(internal)
Total 92729
Stakeholders to be consulted
I have assumed that Gayle Peacock will be the Business Sponsor for this opportunity.
The stakeholders shown below have been identified as key to the development and successful launch of this activity.
* Gayle Peacock, Anne Allaker and Angela Van-Den Bogerd — Business Improvement Programme
® Julie Thomas Allen Kambasha, Angela Bunyan — Network Stakeholder Engagement. Julie is also the work stream owner for
training on the Business Improvement Programme
* — Branch User Forum — this forum is chaired by Angela Van-Den Bogerd and the SLT members include Paul Brown, Michael
Larkin and Dave Hulbert. This is a forum to discuss agent and operator concerns and test ideas.
* Naomi Sayers and Jonathan Knox — Comms
e Shaun Turner, David Hodgson — Branch Standards Team
* Sue Richardson — Network Operations Team Project & Standards Manager
* Sandra McBride, Lee Heil — New entrants process
© Warren Hattrell — Field Team Leader (representative of many at the sharp end)
— Risk & Compliance Business Partner and Product lead — varies with the topic — maybe Georgina Blair could pick this area up
* Nick Beal, Stefania Ugliati— NFSP relationship team
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The Proposal
IMPORTANT: It is suggest that for each ‘Stage’ implementation, a ‘Control Group’ is used in the first instance to draw
out any further enhancements that must and should be made, prior to the full rollout to the user group identified.
Any ‘nice-too-haves’ will be documented and considered as part of any future enhancements.
It should be noted at this point that the proposed solution for new joiners described below is the same solution that
would be deployed for the future stages.
e Stage 1—New Joiners {before March 2014 ??}
To host the Compliance Training modules and tests online so they can be accessed by new joiners using their own
devices (computers, laptops, tablets, smart phones) at a time that is convenient for the user.
The new joiner would be provided with a ‘link’ to access a secure site at which point they would be required to
provide the appropriate registration details, including a user name and password, which will be linked to that
individual as an employee/agent of the post office (i.e. traceable against known individuals for example by pay no?).
Once completed, the user would have access to all the appropriate compliance modules and associated tests, which
would then need to be completed. On successful completion, the user would be issued with a ‘Pass Certificate’ for
each compliance module which would be stored locally (for future user access) and centrally (for management and
audit purposes). The ‘Pass Certificate’ would be available for printing as a physical record from the site, emailed and
potentially sent as a PDF to the users mobile device
In relation to the management and auditing of the completion and non-completion of the modules, detailed
reporting will be provided and ‘Super User’ access will be available to the appropriate departments and individuals
as requested by the business. In addition, capability can be provided in the form of automated ‘alerts’ which would
be despatched via email and/or text message to the user where it has been identified that compliance training has
not yet been completed. These same alerts could also be made available to the management team for appropriate
action to be taken.
The Benefits
Y No need to provide physical work books as the content is held online
Y No need to complete the manual test that then requires marking by the trainers, as the test and marking is fully
automated online.
¥ Removes the requirement on the trainers to mark the tests, as this is provided by the automated online solution.
Y No need to complete the compliance test again on Horizon in order to obtain the ‘Pass Certificate, as this is
provided on successfull completion of the online test.
Y Asolution that enables the user to complete the compliance module at a time and place that is most
appropriate. (including at home on their own devices)
Y_ Aproof of ‘pass’ solution that offers flexibility to prove that the user is compliant, via a physical pass certificate
or a pdf version held on a mobile device.
vY Auser repository that can be accessed to obtain the ‘Pass Certificate’ when it has been lost, removing the need
to retake the test on Horizon.
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Y Acentral management, reporting and audit solution providing real-time information that can be used to
proactively take action on compliant and non-compliant results. This does not currently exist based on the
information provided to date.
Y Anefficient and effective solution for delivering updates, amendments and new compliance modules, when
required. Potentially, overnight dependent on the nature of the change.
Y Potential removal for the need to physically audit a branch, as the required information is available from a
central online repository.
¥ Amechanism that can be used to demonstrate to the Information Commissioner's office and regulatory bodies,
as well as 3" party business partners and clients (e.g. Govt, CAA) that Post Office Ltd have a robust and auditable
solution in place to deliver and manage compliance for staff providing products and services within our branch
network and that we are therefore compliant with both our legal and contractual obligations.
Y Data matching and live feed between the Learning Management System and the HR Management
System/Branch Network Personnel Database?
Need to obtain visuals from EMC — workshop to be arranged
Future Rollout
e Stage 2 — Directly Recruited by Agency Branch (before March or June 2014 ??)
Basically rollout the solution described above. However, consideration needs to be given to the P250 process and
how this can be linked to compliance training completion. Need to discuss with the appropriate stakeholder
community.
e Stage 3 - Existing Agency Branch Colleagues (before September 2014 ??)
Basically rollout the solution described above, with a few tweaks. Need to discuss with the appropriate stakeholder
community.
GAYLE PEACOCK: I would like to test here this in conjunction with the availability of tablets/devices
e Stage 4 — Existing Directly Managed Branch Staff {before March 2015 ??}
Basically rollout a similar solution tailored for directly managed staff. Need to discuss with the appropriate
stakeholder community.
GAYLE PEACOCK: I think this one could be rolled out first and pilot the approach as all Crowns have access to a
computer.
The initial and future rollout proposals are subject to change following consultation with the Business Sponsor and
appropriate stakeholders