What am I talking about?
In this instance, I’m referring to assessing training needs and evaluating the effectiveness of the delivered training on a group basis. The FCA guidance within the TC Sourcebook states that firms should assess the training needs of their staff at the outset and regular intervals. Appropriate training and support should be provided, and the quality and effectiveness of such training should be reviewed.
The FCA’s guide to recruiting, training, and supervising staff outlines examples of good practice, including establishing an appropriate initial training plan for new starters, having a training plan in place for the forthcoming year, scheduling training events in advance, and regularly evaluating the effectiveness of training.
Well-trained staff deliver better customer outcomes. They provide better service, make fewer mistakes, and handle customer issues more effectively, thereby improving the customer experience.
Yet firms can and do neglect this area. In 2024, the FCA imposed several fines on firms where inadequate staff training significantly affected the identified failings. These included inadequate staff training, leading to the agreement of unaffordable repayment plans and incorrect fees, as well as insufficient training to equip staff to identify and mitigate financial crime risks adequately. Inadequate training has also contributed to staff being unable to provide suitable support to customers experiencing financial difficulties.
Well-trained staff deliver better customer outcomes. They provide better service, make fewer mistakes, and handle customer issues more effectively, thereby improving the customer experience.
We are often approached by firms seeking refresher training on Conduct Rules or an event that addresses Regulation or Consumer Duty based on a hunch or a feeling that something needs to be done in that area. That is okay if all your staff are on the same level, but what if some are new to the role and some have 15 years of experience? They will have different training requirements.
A Training Needs Analysis (TNA) is all about ensuring that the training designed and delivered is effective. It helps identify specific gaps in knowledge and skills and confirm that the designed solution is appropriate. It also avoids wasting time and costs on ineffective training.
Despite the compelling arguments for a TNA, remember there are times when it might not be necessary. For example, where everyone should be aware of specific legal and regulatory requirements. A TNA is relevant, though, for most types of training. It ensures a systematic approach is applied to identify and agree on the goals, objectives, strategy, and how the results and effectiveness will be measured and evidenced.
So, where do you start?
Ideally, you would first conduct an organisational needs assessment, filtering down to departmental needs and then finally to individual needs assessments. An organisational needs analysis typically requires the support of senior stakeholders and is often triggered by a transformational event or when actual organisational performance falls short of expectations. Sometimes, we want to know what staff need to do their role more effectively, which can be a tactical and strategic activity.
The steps include:
- Identify the organisational goals
What do you want to achieve as an organisation? Understand the objectives and areas of growth. Determine any external and legal constraints.
- Requirements analysis
Is this the entire workforce, a department or role by role? How will you measure the capabilities?
- Job analysis
For each role in scope, determine the required and desired tasks, knowledge, skills, and competencies
- Assess the current knowledge, skills and competencies
Evaluate the skills, knowledge and abilities. This can be done via the outputs of your competency-based assessments, 360-degree feedback to provide a more rounded view, performance data, TNA questionnaires where the individual rates themselves, surveys, and interviews
- Identify the gaps
Determine the difference between the current and required/desired knowledge, skills and competencies
- Prioritise the needs
Review the identified gaps and prioritise the most critical ones that will have the most significant impact on your organisational goals
- Develop the evaluation and effectiveness measures
Several models can be employed here, each with its strengths and weaknesses. However, it’s probably not the model you use but how well you execute it.
I use the Kirkpatrick Model to identify and define measures and indicators, starting at Level 4 (Results), which is the actual reason you are conducting the training in the first place. Level 3 (Behaviour), Level 2 (Learning) and Level 1 (Reaction), which is usually some form or survey completed at the end of the training
- Develop the training plan
Create a plan to address the identified needs, including what type of training is required, the timeline and resources required to deliver
- Implement and evaluate
Training is an area where companies frequently look to reduce costs. However, the greater importance and value that firms place on the quality and effectiveness of their training will always be a key differentiator in delivering good customer outcomes.
About the author
Lynne Hargreaves is the Director of ClearStep Consulting, a consultancy specialising in FCA regulation and its people impacts. This includes the provision of training and consultancy services.
Relevant links and sources
https://www.kirkpatrickpartners.com/the-kirkpatrick-model/
https://www.fca.org.uk/firms/recruiting-training-supervising-staff
https://www.handbook.fca.org.uk/handbook/TC/2/?view=chapter
https://www.handbook.fca.org.uk/handbook/SYSC/5/?view=chapter
