Q&A with Nicole Tarasoff

Interactive compliance training presents:
Q&A with Nicole Tarasoff

Nicole Tarasoff is a writer-turned-compliance officer living in the San Francisco Bay Area. After graduating from Arizona State University with a BA in English, Nicole found herself working in the financial sector as a risk analyst, where she developed an unexpected passion for simplifying the language of compliance. Nicole later served as a head writer and compliance program consultant for NYSE Governance Services (formerly Corpedia), where she advised both public and private companies across a broad swath of industries on E&C best practices, authoring over 100 codes of conduct and related policies during her tenure. Currently, Nicole is a senior compliance manager on LinkedIn’s small but mighty Global Compliance & Integrity team, where she spearheads the company’s compliance training and program build, communications, and culture initiatives. She continues to advise key stakeholders on compliance matters affecting the business, and participates liberally in pro bono activities impacting the surrounding community.
Q1. In your opinion, what makes an effective compliance training program?

I think an effective training program takes into account the complete user experience and really seeks to understand and accommodate the different ways that people learn and retain information. Oftentimes, companies are laser-focused on meeting regulatory obligations and immediate or enduring risk-mitigation needs, which I get. You need to get it done. But if you’re not thinking about who you are training and why, how often you’re training, and what kind of experience you’re providing, then you’re not working toward an effective program. Completion rates will only take you so far. Teach people in a way that facilitates learning and contributes to their success. Connect laws and policies to values and leadership skills. Solicit feedback and take action accordingly. And find ways to continuously test knowledge.

Q2. What communications strategy do you use to help launch mandatory training efforts?

I leverage every available outlet, and I seek to partner with our Comms team, HR, and all levels of leadership early on to gain support. Cascading messages are key; it’s not enough to just have our exec staff communicate the who, what, where, when, and why – we really send engagement into overdrive when we have continued follow-up messaging from managers, directors, and vice presidents. That’s really the bulk of it. Everything else – digital signage, LinkedIn posts, intranet articles, and mentions at our global all-hands meetings – is the icing on the mandatory compliance training cake.

Q3. On average, how much time every year do you think staff spend on mandatory training and should that time be protected?

On the compliance training front, I’d say about 90 minutes on average. Some years, like 2018, are more time-intensive approach is required to account for changes in the regulatory landscape – GDPR, obviously, and audience-specific needs, like California’s two-hours-every-two-years requirement on sexual harassment training for managers (or AB 1825, if we’re keeping things simple). I don’t know that I can say with confidence that anyone’s training time is necessarily “protected,” but we place a big emphasis on learning in general here. Our leaders know to account for this time, and we continue to iterate and improve, in order to optimize schedules and avoid conflicts.

Q4. How important is it customize your training and what sort of customization do you do?

Custom training is mission-critical for us. As a compliance professional, I completely sympathize with budget constraints and other resource limitations – headcount, cross-functional partnerships, only having 24 hours in every day – but there is nothing that tells a learner you care more about their experience than tailoring the content to your company. There are a lot of cheap or free resources out there that you can leverage to develop custom materials. And when you think about the cost to license generic OTS content, the up-front investment in a course you own outright has a pretty good ROI. When there are courses that I don’t feel confident we can build completely from scratch, I want to put as much of my imprint on an OTS solution as possible: custom scenarios that illuminate the types of misconduct we actually see, practical ties to our culture and values, and all the specific terminologies and resources we’d actually use.

Q5. What’s the biggest challenge you face every year when it comes to compliance training?

No matter how many times I launch a training program, no matter how well I’ve documented a process, and how closely I follow that process, something is always going to throw a wrench in my plans. I’ve learned to anticipate and plan around it. Honestly, the biggest challenge is trying to get the timing down right in order to meet our training requirements, while accommodating various business schedules, global holidays, and major business deadlines. It’s never perfect, and it’s never easy, but it’s worth it to be a partner to the business and find the best possible compromise.

Q6. What’s the best piece of advice you’ve ever got on putting together your compliance training program?

I wish I had a pithy one-liner for this. The best advice I received on building a training program was to put the extra effort into targeting the audience. It was really stressful for me to plan this out on the back-end at first, in order to actually create and maintain accurate transcript assignments. But then I remembered being a writer early on in my career and having to take anti-corruption training when I had literally no contact with government officials, and if I did, I had nothing I could reasonably offer them. How are you supposed to engage with content that takes up to an hour of your already busy day and teaches you nothing of practical value to your job? It’s worth it not to put people through that – even if it requires a lot of quality assurance behind the scenes to get the right filters in place.

Q7. What are your training pet hates?

I can’t stand training that is disingenuous, cheesy, full of easily dated cultural references or slang, or that otherwise tries too hard to be hip and edgy. And while I think there are some great gamification models out there, there are many more that are sort of half-baked homages to classic games with some stodgy policy-language shoehorned in. As a gamer myself, it’s really hard for me to watch a demo like this and hear a pitch that amounts to: “Engineers will love this!” Yeah, I’m not so sure about that.

Q8. What’s been your biggest success and why?

Building out a compliance training and communications program that went from paltry participation to 99%+ completion rate in just under three years. There’s tons of room to improve, expand, and mature, but I’m incredibly proud of what we’ve accomplished in such a short time, and for such a small team.

Q9. What innovations are you seeing in current training and do you think there is anything missing currently?

I appreciate a clean, modern, global aesthetic in all trainings, and I especially love video-based courses. I think more compliance learning should take the shape of a short-form documentary or master class that really engages learners from the start, and gives them access to knowledge that they actually want to share and discuss with their peers. I also think there’s a huge gap in the amount of accessible courseware on the market – training that thoughtfully accommodates users of all abilities.

Q10. If you could give one piece of advice to anyone thinking of training their employees, what would it be?

Focus on the human aspect. Yes, you have regulatory requirements and board mandates, and all manner of internal expectations to contend with. But you’re not going to win the people over by prioritizing prohibitions and punishments. Teach people how to be thoughtful, respectful, and ethical leaders. Show them how to make decisions that honor your corporate values, so they know how to measure their successes in those same terms. Respect their time, and give them content that is relevant to their job function. Think less about the boxes you need to check, and more about the people, and I promise you it will make a difference, not just in your completion rates, but in how engaged and invested your employees are.

“…there is nothing that tells a learner you care more about their experience than tailoring the content to your company.”