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Introduction

My name is Kevin Avis. I am one of the business partners in the People Development function of Circle Health Group. Circle Health Group is the largest independent private healthcare provider in the UK. We’ve got around 60 services. There’s a number of services, largely private hospitals, from Aberdeen right down to the bottom of the country. We’ve got some sterile services, decontamination services as well for our hospitals and they also support other hospitals. And we also have community outpatient services as well. So they’re kind of the key services that we deliver in Circle Health Group.

What does compliance mean for your organisation?

Yeah, compliance is critical and it’s a non-negotiable for anyone in the business because fundamentally at the centre of everything we do, and it is embedded in the way we look at things for our beliefs and philosophy, is that people are at our centre. So whether they’re a patient, our employee or some of our extended workforce, their experience and their outcomes are really critical. So therefore, anything that we can do to ensure their safety, their wellbeing, and their outcomes, we take very seriously. So I think compliance can appear to be something that’s dull mundane, but behind every tick or every check or behind every click, there’s a person behind that and that’s the reason why we do it.

How do you assess behavioural compliance?

I think that the best way that we’ve managed to do that is embed our philosophy through everything that we do. So the key things, from our side at least, but from a whole HR side and across the businesses, is embedded in our systems and practices. So we’ve what we call an operating model. It’s embedded in our induction. It’s embedded into our appraisal process and our talent management process. So particularly how we use Totara is, in our system, is making sure that the behaviours are embedded into the induction in the appraisal and also through our 360 degree feedback tool as well. So they all contribute towards the culture and provide a sign post for how people do the checkbox, but also how they act that out. So there’s lots of tools that we use in the system to support that more behavioural approach as well.

What is the user experience like?

So the key thing is obviously we’ve got kind of our own induction dashboard where we’ve got lots of downloadable resources and this is really like a resource hub that people can tap into. So this is a typical induction page that we have. And obviously we’ve got things like welcome videos and policies and benefits and the whole thing around governance and assurance, that’s really important that people pick up. And the relevant induction manual as well that refers them to the right guide for them, which in that case, all the behaviours and policies are embedded throughout that as well.

And we’ve kind of added in, things around our patient journey and videos from the exec as well and the people team. One of the more critical things around behaviour is around 360 tools. So we created this feedback hub. We brought together the resources element of this section, so the micro-learning bit, a 360 degree tool that our provider was able to provide and also talk about different ways that people can use feedback across the business.

So for example, we created this feedback matrix here that identifies the different tools against the type of feedback and how it’s supposed to be structured. So you can see that these tools here, like the check in tool, the nine box grid, and 360 degree feedback appraisal, they’re all things that we use in the system.

So people can access the feedback resources. Here for example, we’ve got all these different ways about how people can give feedback and how that is accessed. A workshop, we’ve got an identifying talent guide as well that we’ve written, that allows people to work out from a nine box perspective, how people might develop, how they might grow and what their next steps are, and what kind of behaviours people would want to see within them. 

So this allows us to put in the structure of the 360 feedback and what we want it to be, and then how we rate it as well, and what the skills are relevant to those, or if it’s an open text field, et cetera, et cetera. And this allows us to be really agile and flexible. To how, we want to see our behaviours and our beliefs embedded in the business. Because I think from our perspective, when we see people that differ from what we think they should be, it’s not always a hard line approach that we should take, but it should be a developmental approach sometimes, And we’ve been really clear in our business that this is a developmental approach.

Do you use competencies to measure compliance?

So we’ve used the competency toolkit to do this. I’m gonna show you my own. So you can see here that management leadership is one of the ones that we’re working through. And actually I’ve got to do my own. And you can see that We're working through this ourselves. And what we’ve done is use this to provide a more kind of interactive way of looking at competencies around this so you can dive into it if needed and you can drill into it, rather than what’s come out the box. And that feedback has been really positive for where we’ve launched this.

How do you report on compliance?

What we’ve done is that we have used the tool to push out a report from the system every day. The key reports are around our appraisal data and our training compliance data. And what we’ve actually done is because people have seen the success of the system and how it can produce a percentage, is we split our compliance training down into role specific and mandatory. The people can see the mandatory training here, but there’s also different training that’s required because of that individual’s, registration or that individual’s, area of practice or specific responsibilities that people want assurance that that training is being done. So this is a good example of us splitting this down as well.

So that, that’s the first thing that we’ve done. The next thing that we’ve done is we use PowerBI as the source of data. The investment in this has been an absolute lifesaver. On a Monday we used to take the reports from Totara and turn them into a number of Excel sheets that would go out to the business. And it was about 50 megabytes of data every week that was going out, and we could only report officially once, once a week. And that put a lot of pressure. On us as a team, and when I first came into the business, 80% of my job was to do with compliance. And because of the system and because of a tool like PowerBI, that has probably become 5% of my job, 10% of my job, because this becomes the, the source of truth.

And what we are able to do now is have a very dynamic view of the compliance in the business and it is very transparent that anyone can see anyone as they need it to be, so what we’ve made sure is that from a governance perspective, that we’re reporting on the right things and that’s why we split mandatory and rule specific. The other thing that’s critical and the other thing that the system has allowed us to do, is behind every certification in which I’ll just show you. This, this was really powerful to us in that, when we assigned the certification to someone, it immediately showed them as not compliant. Whereas actually we used this setting in the back of it to say everyone’s got a hundred days to complete it, so if they had been newly assigned it because they’re a new starter or they’re new to the business. And that was really powerful for us to kind of make sure that the reporting was accurate, because what we found when we were doing the Excel sheets, et cetera, et cetera, years ago, was we were never really able to correlate compliance with turnover or business development. So one of our hospitals might develop a new theatre and employ 20 people as a result of that. And if they’ve got 200 people in their hospital, that would drop their compliance by 10%, which is quite significant sometimes.

So by using the settings and also by using the data in Power bi, we’re now able to cut and slice the data as we need it. And the default data, excludes new starters and nearly assigned, which is what that setting does. And keeps us at a compliance level that’s allowed and also allows people in the business when they’re newly assigned training to have that breathing space to do it rather than feeling like they have to do it straight away.

How do you support Managers in monitoring compliance within their teams?

The reason for the noncompliance is because I’ve got a test account on here, but I’m able to see what’s due soon and their overall percentages as well. And it’s really clear for management what they need to do. The, other thing that we’re working on as well is we’re using the scheduled reports, and we’re doing some development where we can change the subject line and add in some rich text and we’re gonna automate. exception reports, or escalation reports are probably the more the right thing where senior managers have not been able to get the staff to do the appraisals on time, or their mandatory training, is that they’ll be reported on a weekly basis.

There is a leaderboard as well that is used. It, does create an area of competition between the executives and they want to make sure that they’re number one as well. And I think competition is helpful, to make sure that compliance is right. And actually the good thing is because it’s so transparent, it’s used in every area of the business, whereas we were previously the gatekeepers to that information and people would have to come to us and obviously that would depend on us being available. Now, we’ve just kind of given it to the business, and we know it’s used everywhere, all over the place. And it’s very transparent and very clear, which we like. I think that’s really helpful for us.

What is the role of HR or L&D in maintaining compliance levels?

We’re responsible for providing the framework, providing the training and providing the reporting. It’s not our responsibility to own everyone’s compliance, and it is a multi-stakeholder approach where managers have to take control and individuals have to take responsibility. The subject matter experts in the business, have to understand what’s going on with their training in the business. And we know that every governance committee refer to this dashboard as well. and behind this is a responsibility metrics around who’s responsible for what, at what level, for what course. So we’ve thought about that really carefully, where we can advise and support. And actually because of all the automation, it’s really reduced our workload from a central perspective as well, and actually it’s provided a huge amount of clarity back to the business. And because it’s all automated, there is less room for error.

How do you know if a compliance initiative has been a success?

Our governance is responsible for making sure that learning that is deemed as compliant is that that committee and the chair of that committee are responsible for that learning. And across the people development team in the business that we would partner with different areas of the business to make sure that is the training that’s being provided relevant and does it meet the minimum requirements of what we have to do and actually is it making an impact in the business.

What tips do you have for other organisations?

I think it’s really important to be structured and as unambiguous as you can around training, and who it’s assigned for, and the lesson that I’ve learned and the businesses have learned is that aligning yourself to agreed conventions in the business is really important. And not trying to create a different way of understanding who people are. At the beginning, have a really, really clear structured convention of how training is to be delivered and to be allocated and make sure that is eighty percent binary, and then there’s 20% that remains unambiguous sometimes and, and use the system to its strengths to try and manage that ambiguity as much as possible.

So using things like the audiences, and have clear set of audiences that are based on that binary data. And if it can’t be matched, using things like profile fields to try and capture information to see if that person’s got a specific responsibility or skill set or whatever. I think that’s critical. I think also, a coding structure, around the courses is really important.

So audiences and courses and certifications all have the same code and, and if things change and naming conventions change over the years, which they do, then you don’t get lost. Well, what happened three years ago with that course? So they’re kind of things that’s really important.

I think also being reasonable to staff around what’s expected. So we’ve got a hundred day rule, and everyone knows that, and that allows us to be reasonable about changing training and allocating training. And that also allows us to be clear in our policy about what we measure. I think the last thing is also being realistic about what needs to be mandatory and not mandatory.