Best practices for protecting learner data
In the post-COVID-19 era, corporate e-learning efforts are experiencing explosive growth. Part of the reason is due to the rise of remote work and geographically dispersed teams. Unfortunately, there are always growing pains when scaling a company’s efforts too quickly. For e-learning, one of the growing pains is that data privacy standards tend to fall by the wayside. This is a critical issue for businesses looking to meet the challenges posed by the large amounts of new data collected by LMSs and connected analytics tools. To improve the situation, affected companies must redouble their efforts to establish viable e-learning data privacy standards and practices. Here’s a primer on corporate e-learning data privacy.
Scope of corporate e-learning learner data
To protect learner data, companies must first define the scope of what needs to be protected. Obvious data in scope includes personally identifiable information (PII), user performance metrics, and behavioral data. However, corporate e-learning programs often collect much more sensitive information than these. 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 important to recognize that employees may be underestimating the data that employers collect through e-learning platforms and courses. Therefore, it is important to establish transparency regarding data collection practices and applicable data privacy measures. This is key to managing the risks and liability associated with data loss or theft.
Business risks from poor data privacy practices
Lacking eLearning data privacy practices can expose your business to various types of risks. The most immediate risk is that your LMS or related systems will fall victim to a cyberattack. This would result in immediate financial and reputational loss. Such systems are attractive targets because attackers know they usually have weak defenses. Additionally, a successful breach can expose everything from employee PII to performance data and even sensitive regulatory compliance information.
But an even bigger risk comes from the erosion of employee trust caused by data breaches. For example, imagine that information about employee performance, or even worse, psychological evaluation data, falls into the wrong hands. It can be difficult to convince employees to divulge such information again. This can immediately undermine the effectiveness of a company’s entire e-learning program.
Additionally, certain companies have legal obligations to protect learner data. For example, companies subject to GDPR and CCPA must follow strict data protection guidelines. Failure to do so could result in hefty fines and subsequent onerous reporting requirements from regulators.
The role of data privacy in fostering a strong learning culture
Minimizing risk isn’t the only reason companies are improving their e-learning data privacy practices. Doing so is also essential to creating an effective learning environment. Just as data loss can lead to a devastating loss of employee trust, strong data privacy practices can create employee trust. This increases employee engagement and helps them participate more authentically. Recognized and rigorous data privacy practices create the psychological safety necessary for employees to feel free to participate in sensitive training. It also sends an unmistakable message that the company values employee privacy. Employees typically reward their employers in kind and act as good stewards of company data.
Six Key Principles of a Smart Corporate E-Learning Data Privacy Program
The good news is that it’s not difficult for companies to create and implement a smart eLearning data privacy program. Most of what you need falls into six simple categories that, when combined, form the principles of a viable data privacy approach. They include:
1. Minimize data
The most important thing companies can do to support data privacy efforts is to collect and store as little data as possible. For that, it is important to accept the concept of data minimization [1]. The idea is that organizations should only collect data that is “reasonably necessary and appropriate.” In other words, companies need a concrete reason to keep certain data and dispose of the rest.
2. Defined data purpose
A corollary of data minimization is that companies need to enumerate the reasons for collecting and storing data. Otherwise, it is almost inevitable that your business will experience data growth. This occurs when unclear guidelines cause data to be stored beyond what was originally approved. Everyone involved in managing a company’s eLearning infrastructure needs to know clearly what is data and what is not. Reporting and data pruning processes must also be defined to prevent and remediate unintended data growth.
3. Access control
Data privacy requires tight control over access credentials. Companies should adopt the concept of the Principle of Least Privilege (POLP) throughout their e-learning infrastructure. This means having a clear user access provisioning process, an offboarding process to remove credentials for departing employees, and regular reviews of all user access rights.
4. Encryption and access security
For companies with remote teams, secure access to a company’s e-learning infrastructure is critical to maintaining data privacy. This should include full encryption of data at rest. This prevents unauthorized persons from copying and using your protected data without the necessary decryption key. Additionally, it is important to ensure encryption in transit for all remote team members accessing your protected systems. All you need to do is partner with one of the best VPN providers and restrict access to its endpoints. [2].
5. Strict vendor management
Some of the largest data breaches in history occurred not because primary security measures were inadequate, but because of inadequate safeguards put in place by third parties. As such, careful due diligence is essential for any external vendors that may require access to a company’s eLearning infrastructure. All third parties must be held to the same data privacy standards as the company itself. Otherwise, there should be no unrestricted access to sensitive data.
6. Complete audit trail
Finally, companies must maintain a complete audit trail that records access to protected data. This provides an easy way to investigate suspected misuse of sensitive data. This should include access time, date, user credentials, and access method. Some LMS systems have built-in audit logging capabilities. For systems without built-in logging, there are standalone solutions that can monitor access to almost any type of data source.
Data privacy is the foundation for effective corporate learning
After all, companies have good reason to put data privacy at the center of their corporate e-learning initiatives. Risks are reduced and training efforts become more effective. Additionally, there is no downside to data privacy initiatives other than the direct costs they incur. So, as the number and scope of corporate e-learning initiatives continues to expand, it’s worth the effort to take the time to evaluate your data privacy practices and improve them where necessary.
References:
[1] Minimize data
[2] How to use a VPN
