Today we conclude our series on data analytics with a look at one other critical capability it can deliver for you: better reporting.
Better reporting to whom? A wide range of audiences: senior executives, the board, regulators, business partners, merger partners, leaders of operating units, and even you the compliance officer.
Better reporting about what? A wide range of issues: which elements of your compliance program work well, which ones don’t, disparities or gaps in the compliance program across your enterprise, quantified insights into your audience’s behavior, attitudes, perceptions, self-reported actions, and more.
Even better, you can see how these things shift over time in response to your compliance initiatives — giving you evidence-based feedback about which approaches, tools, messages, and channels really work (and also which ones have limited value).
The right approach to data analytics helps you generate more data and improve the quality of the data you collect.
In our experience, most compliance teams who struggle to get started with data analytics have one of two problems:
1. They don’t actually have useful data. Most data traditionally collected by compliance teams (outside of large, labor-intensive projects like program or risk assessments) tends to be simple quantitative data that can tell you a little but not a lot, like:
- 94% of the audience we assigned the course to completed it
- 100% of learners passed the test question on bribery
- Average time spent per page: two minutes, but some people spent up to 20 (sidebar: In our multi-tasking world, this will never be a useful statistic — and the fact “time on page” is cited so often in compliance analytics discussion shows just how little real data we have traditionally had to work with)
- In 2022, the helpline got x reports, which is up y% from last year, and the top topics were these five: a, b, c, d, e
In our experience, behavior metrics like these are a starting point — but they often only yield true insights when paired with qualitative data in quantified form. This becomes even more powerful when you can correlate results across multiple data sets.
For example: “Our Exports Compliance course has a year-over-year completion rate of more than 95%. However, in the course, we quizzed people on which of our products were subject to export controls — and only 24% answered correctly. As a result, we think there is more work to do. We are going to create quick guides that include a “can I export this?” decision tree, and then we will re-test the same population in six months to see if anything has changed.”
Simple quantitative data is one-dimensional. You can see what is happening, but you can’t see why. You can measure and report on the compliance program’s activities, but not really its performance.
2. They’ve received some potentially useful data but in the form of a dashboard or a data dump. Some analytics solutions provide a feed or report of raw data — but no help organizing or making sense of it. (As one client put it: “When I hear the word ‘analytics,’ I think: ‘So what’?”)
Three years into delivering our Drive Analytics™ solution for our clients, we are more convinced than ever that data alone is not the answer and simple software solutions are not enough. The missing ingredient? Human intelligence powered by compliance expertise.
In other words: Data is your jumping off point — but the detective work to unpack it is what unlocks its value.
Let’s take the example of tracking activity in digital Codes. Yes, it is genuinely useful to know that 23,485 unique users visited your digital Code last year, a 27% increase from the time period before that.
However, it’s even more useful to uncover why — which requires correlating the Code activity data with other information, which no piece of software can do for you.
- Let’s say you don’t know why visits increased? In that case, you have some further detective work to do, maybe via surveys, maybe via questions in a training course.
- Or let’s say, instead, during the reporting period, you intentionally increased your Code messaging, creating a campaign that included a poster, an online video, and messages from management. In that case, you can conclude your Code campaign worked! Also, the channels and messages you picked got results, so you can use them again for other compliance messages.
Making Your Reporting Matter
In this series, we’ve already covered how to put the infrastructure in place to collect data. Let’s now focus on creating meaningful reports.
A few tips for better data-based reporting:
1. Remember, simple activity metrics alone don’t tell a story. When you’re creating reports, ask yourself: What do I want my audience to DO with this information?
Ideally, you want your data to illuminate a desired next action. Review your activity metrics and ask yourself: Is there anything interesting here? If not, your only message needs to be: Seems like this is functioning fine. Then look for something that’s actually interesting.
2. Collect more data to paint a fuller picture. If you already collect quantitative data, don’t stop! But look for ways to add more data (especially the qualitative kind) to round out your perspective.
For example, let’s say you collect and report on course completions. Dig into that a little bit. Yes, people completed the course — but were they the right people based on job role? Did the course adequately make the case that this topic matters?
To find out, next time include a question asking learners if they felt the course was relevant to their jobs. Then tie the two together in your reporting: We achieved a 99% completion rate for our bribery course, and 92% of those who took it said “Yes, definitely” when asked if they felt the course was relevant to their work at the company.
3. Put work into analyzing the data. You won’t always know what the data is telling you right away. You won’t always know what other data sources it will be useful to correlate with. There’s simply no substitute for someone with compliance expertise doing the hard work of reviewing the available data and spending time and thought trying to make sense of it.
For this, you need someone who 1) knows your business, 2) has deep compliance expertise, 3) is familiar with your compliance program’s activity and goals (and compliance programs generally), and 4) is comfortable reviewing and interpreting data. This is high level work!
In today’s regulatory and business climate, the Justice Department wants to know whether your compliance program is working, not whether it’s busy. Along similar lines, corporate boards are under more pressure than ever before to assure that their organization’s compliance program is effective. A “busy” compliance program that still allows violations to happen can be their worst nightmare.
Structured wisely, data analytics brings correlations and trends to light that otherwise go unseen. That, in turn, allows executives (including you) to ask better questions about why those correlations and trends exist, and to make decisions with better confidence.
When people ask for “better storytelling” via analytics, this is what they mean. Today’s stakeholders want multi-dimensional reporting that illuminates why your company’s culture of compliance is the way it is — and what you should do next to improve it. That is what effective data analytics can deliver.
Good data analytics can also help you uncover new insights that might have strategic value (“we have sky-high anti-corruption risks in our overseas unit that nobody is taking seriously”), and that might let you gain entry into management’s executive decision-making. The compliance team can become a more valued, more strategic asset for the whole enterprise — all of it based on your ability to provide more valuable reporting.
Adding value via data analytics also opens doors to more relationships with more parts of the enterprise. And once you prove you can do something useful with the data you control, you may find it easier to gain access to data owned by other parts of the organization.
And Other Benefits Too
As much as we love data analytics, compliance officers do have a day job running their compliance programs: conducting investigations, developing new policies, leading training sessions, and the like.
In a roundabout way, data analytics can help with all of that too, because it (1) alleviates the burdens of collecting and analyzing data manually; and (2) allows you to focus on those issues or tasks that deliver the most impact. It allows you to devote more time and energy on high-value tasks, rather than spending your time (or your team’s time) on tedious work.
Ultimately, that data-driven better reporting leads to a cycle of self-improvement. That is, better reporting allows you to have a more responsive, more effective compliance program, which leads to better behaviors, which lets you tackle other problems, which leads to an even stronger culture of compliance, and so forth and so on.
That’s the ideal state every compliance officer should strive to achieve. Data analytics makes it possible, and there’s no reason not to start building that analytics capability today.
