Best Practices For Protecting Learner Data
There's been an explosion in the growth of corporate eLearning initiatives in the post-COVID era. That's due in part to the growth in remote work and geographically distributed teams. Unfortunately, there are always growing pains when any corporate initiative scales up in a hurry. In the case of eLearning, one of those growing pains is a tendency to let data privacy standards fall by the wayside. That's a significant problem as businesses try to navigate the challenges posed by a flood of new data collected by LMSs and connected analytics tools. To remedy the situation, affected companies must redouble their efforts to establish workable eLearning data privacy standards and practices. Here's a primer on corporate eLearning data privacy to help them do so.
The Scope Of Corporate eLearning Learner Data
To protect their learners' data, businesses first need to define the scope of what requires protecting. The obvious data that falls within the scope includes personally identifiable information (PII), user performance metrics, and behavioral data. However, corporate eLearning programs often collect far more sensitive types of information beyond those. Other categories of data that raise privacy concerns include participation in DEI initiatives, ethics-related information, and data from well-being modules.
It's also vital to recognize that employees may underestimate what data their employer collects through eLearning platforms and coursework. So, creating transparency around data collection practices and applicable data privacy measures is vital. It's a key to managing risks and liabilities associated with data loss or theft.
The Business Risks Of Inadequate Data Privacy Practices
Lax eLearning data privacy measures can create multiple kinds of risk for a business. The most immediate risk is of your LMS or related systems falling victim to a cyberattack. That would create immediate financial and reputational losses. Such systems make appealing targets because attackers know they're typically lightly defended. Plus, a successful breach can yield anything, from employee PII to performance data and even sensitive regulatory compliance information.
However, an even bigger risk stems from the erosion of employee trust that would result from a data breach. Imagine, for example, that information related to employee performance—or worse—psychological evaluation data, fell into the wrong hands. It would be tough to convince employees ever to divulge such information again. That can immediately damage the efficacy of the business's entire eLearning program.
Additionally, certain businesses have legal obligations to protect learner data. Companies subject to the GDPR or CCPA, for example, must adhere to strict data protection guidelines. Failure to do so can result in heavy fines and lead regulators to impose onerous reporting obligations afterward.
The Role Of Data Privacy In Fostering A Strong Learning Culture
Minimizing risk isn't the only reason for businesses to improve their eLearning data privacy practices. Doing so is also integral in creating an effective learning environment. Just as data loss can lead to catastrophic loss of employee trust, strong data privacy practices can engender employee trust. That leads to increased engagement and more honest participation by employees. Well-publicized, strict data privacy practices create the psychological safety necessary for employees to participate unreservedly in sensitive training. It also sends an unmistakable message about the importance the business places on its employees' privacy. Typically, employees will reward their employer in kind, acting as good stewards of company data.
The Six Key Tenets Of A Wise Corporate eLearning Data Privacy Program
The good news is that it's not difficult for businesses to create and effectuate a smart eLearning data privacy program. Most of what's necessary falls into six simple categories that, together, can form the tenets of a viable data privacy effort. They include:
1. Data Minimization
The most essential thing a business can do to aid its data privacy efforts is to collect and store as little data as possible. To do so, it's important to embrace the concept of data minimization [1]. That's the idea that an organization should only collect data that's "reasonably necessary and proportionate." In other words, the business must have a concrete reason to keep specific data and should dispose of the rest.
2. Defined Data Purpose
As a corollary to data minimization, businesses should enumerate their reasons for collecting and storing the data they do. Otherwise, it's almost inevitable for the business to experience data creep. That happens as data beyond the initially approved scope gets stored due to unclear guidelines. Everyone involved in managing the corporate eLearning infrastructure should know unequivocally what data belongs and what doesn't. There should also be a defined reporting and data-pruning process to halt unintended data creep and correct it.
3. Access Control
Data privacy demands strict control over access credentials. Businesses should adopt the concept of the principle of least privilege (POLP) across their eLearning infrastructure. That means having a clear user access provisioning process, an offboarding process that deletes credentials for departing employees, and regular reviews of access rights for all users.
4. Encryption And Access Security
For businesses with remote teams, secure access to the corporate eLearning infrastructure is critical to maintaining data privacy. That should include full at-rest data encryption. It ensures that unauthorized persons can't copy protected data for use without the requisite decryption keys. Additionally, it's important to ensure in-transit encryption for every remote team member accessing protected systems. That can be as simple as partnering with one of the best VPN providers and limiting access to their endpoints [2].
5. Strict Vendor Controls
Some of the biggest data breaches in history happened not because of inadequate primary security measures, but because of inadequate safeguards put in place by third parties. That makes careful vetting essential for any outside vendors that may require access to a corporate eLearning infrastructure. All third parties need to adhere to the same data privacy standards as the business itself. Otherwise, they should never have unrestricted access to any sensitive data.
6. Complete Audit Trails
Finally, businesses must maintain a complete audit trail that documents access to protected data. That provides an easy way to investigate suspected misuse of sensitive data. It should include access times, dates, user credentials, and the access method. Some LMS systems feature built-in audit logging capabilities. For systems that lack built-in logging, there are stand-alone solutions that can monitor access to almost any type of data source.
Data Privacy Is The Foundation For Effective Corporate Learning
At the end of the day, businesses have every reason to make data privacy a centerpiece of their corporate eLearning initiatives. It reduces risk and makes training efforts more effective. Plus, there's no downside to data privacy efforts beyond any direct costs incurred. So, as corporate eLearning initiatives continue to grow in number and scope, taking the time to evaluate, and if necessary, improve data privacy practices is well worth the effort.
References:
[2] How to use a VPN
