Regardless of your industry, we believe if you care about your people you want to make sure they’re treated fairly and behave properly. That said, if you are more than one management layer removed from the ‘front lines’ then a secure and high-quality anonymous reporting hotline is essential. A properly scoped, implemented, and managed hotline supports your knowledge about what potentially damaging behavior you can address as well as employees’ sense that they work somewhere that cares about their concerns and is willing to address them.
Clearly, this critical conduit for communication is too important to under-resource. Unfortunately, the difference between a well-executed solution and an ineffective (or worse, liability-inducing) one can be unclear. Like most elegant solutions, the ‘devil is in the details.’ If you are making just a few of the mistakes below you could be leaving your employees, your customers (students, patients, etc.), and your company open to critical damage to your public reputation and threats to safety.
- Breaks in anonymity Having obvious or assumed ways employees will be improperly identified when they want to report anonymously. In addition to compounded legal liability from potential retaliation, employee concerns about broken anonymity will lead them to not report misbehavior, leaving you in the dark.
- Poor communication When people don’t know how to report a problem, they are more likely to talk about it to friends, co-workers, family members, and even lawyers—and you won’t find out about a issue until it is too late. Make sure you’re frequently communicating the various paths for reporting situations as well as why reporting them helps everyone.
- Inconsistent follow up When an employee reports something and never hears back, they may assume the compliance team (and company leadership) are as apathetic about the problem as the people causing it. Ensure your team is trained, empowered, and managed to address, close out, and correct reported issues within acceptable and clearly communicated standards.
- Limited first-touch collection If your compliance team is slowed down because the initial report is limited in scope and lacks the information a coordinator needs to act promptly, your hotline becomes a liability instead of a force for positive change. Whoever takes that first call should be trained and coached on getting the ‘standard’ or basic info plus asking intelligent follow-up questions based on the incident and compliance team priorities.
- Insufficient feedback The health of your caseload follow up is hard to assess and impact because you don’t have visibility. This leaves your team overworked, your cases piling up, and your risks hiding until they begin to smoulder. Partner with a vendor who helps you manage the whole system, and adopt a compliance case management platform that makes it easy for you to check on performance.
- Disparate investigation notes Disjointed or uncollected records lead to messy audits and unverifiable resolutions (especially when IT issues or employee turnover make things worse). Make sure all your hotline issues are integrated with the activities, information, authorization, and conclusions about that case whether it’s in a self-managed file/database or a professional compliance case management system.
- No audit trail Without an audit trail, the information you do collect is subject to tampering and unreliable. Make sure your hotline reports, including minimal information about when and how information has been collected and changed, are stored in a secure system that tracks who made what change, accessed what file at what time, etc.
- Poor service levels Long wait times and rushed calls lead to the real issues. These metrics are simply indicators of the experience callers have on your hotline. Make sure your vendor is accountable for not only the timing and performance of things reported in the phone server but also the quality of the caller experience. Test calls can be a big revealer, but ultimately the culture and heart of the team will win out over your preferences if they aren’t matched.
- Over-prioritize legal concerns When calls are handled purely to create legal records rather than interactions with actual people, you’re missing a huge opportunity. Don’t allow your hotline to be just check-a-box activity when it can be driving quality, safety, and cultural improvement. Collaborate with legal, your vendor, and internal teams to find the right balance of cold data collection and thoughtful engagement to make sure you do what you (legally) can to treat callers with dignity and understanding.
- Unclear resolution and substantiation When callers never find out what happened with the report they made, it seems like nobody cares. Worse, if word will get around that making the report is a waste of time, employees will stop speaking up. Make sure you have two-way communication options, even for anonymous reporters, so you can share properly scoped information about what was done with a report.
- Limited re-communication We are inundated with data and distractions and people will report much later (or never) if you rely on their memory of training 11 months ago. Work creatively to build engaging, relevant, and convenient reminders into your communication plan – and collaborate with other departments whenever you can!
- Lacking integration Compliance is a voice in the wilderness that gets ignored. When it’s up to you to compete for the limited attention of employees you’re bound to miss some valuable ears. Work with training teams, line managers and task forces addressing/reacting to specific problems, etc. to communicate how a well-integrated compliance hotline can support all those efforts.
- Uncelebrate wins Compliance is the unsung hero nobody knows about. When interactions with your hotline, training, or compliance investigators is seen in a negative light people are less likely to engage and report. Find liability conscious ways to announce and celebrate positive impacts compliance has taken part of including improving culture, initiating quality and employee relations fixes, and helping employees see the far reaching impact of their decisions.
The hardest part about getting an anonymous hotline right is deciphering what your performance data is really telling you. You may get a small number of calls and think there is nothing more to be worried about. Or you may get a high rate of frivolous or misaddressed calls (e.g., someone asking for their paystub) and assume that if there must not be anything more concerning going on. Unfortunately, the fact that you don’t know about a problem doesn’t keep it from harming your people. Establish reliable ways to make sure you’re on the right track: benchmark against industry standards, build a culture of continuous improvement, collaborate with peers in your industry to find out what works for them, and get expert advice on how to do this right. Of course, ComplianceLine is here for you with that advice, clarity on the right solution, and service to make sure you’re focused on the issues most important to your stakeholders and your goals.
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