December 16, 2022

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5 min read

Why Online Training Records Are Not Proof of Training

A training completion record proves that a course was accessed. It does not prove who accessed it or whether they engaged with it. The PricewaterhouseCoopers case, in which fines of over one million Canadian dollars were assessed after staff shared answers to internal training courses, demonstrates what happens when organizations cannot verify who actually completed their training. This post examines the regulatory standard, the insurance gap, and how Integrity Advocate helps organizations build training records that hold up to scrutiny.

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Caroline Esteves
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Corporate training serves many purposes. Meeting regulatory requirements. Building workforce capabilities. Demonstrating due diligence. But across all of these purposes, the same assumption is made: that a training completion record is proof that training happened.

It is not.

A completion record is proof that training was accessed. It is not proof of who accessed it, whether they engaged with it, or whether the person on record is the person who actually completed it. In a regulatory investigation or legal proceeding, that distinction matters enormously.

The PricewaterhouseCoopers Case

PricewaterhouseCoopers is one of the Big Four accounting firms and the second-largest professional services network in the world. In a published regulatory investigation conducted by the Canadian Public Accountability Board, fines of over one million Canadian dollars were assessed after it was found that junior staff, managers, directors, and partners of PwC shared answers to internal training courses on auditing, accounting, and professional independence.

The regulator found that PwC had failed to establish policies and procedures to provide the firm with reasonable assurance that its workforce was completing required training as intended.

This was not a small organization with limited resources. This was one of the most sophisticated professional services firms in the world, with dedicated compliance infrastructure. And still, the internal training program failed to verify that the right people were completing the right training.

If it can happen at PwC, it can happen anywhere.

What Regulators Actually Require

Conversations with private company leaders reveal a consistent gap in understanding. Regulators generally do not stipulate specific oversight requirements for how training must be delivered or verified. They specify the outcome: that the workforce is trained.

The assumption that providing access to online training satisfies that outcome is where organizations get into trouble. Online training records are proof of training accessed, not training completed, and not by whom. Company leadership often has no evidence of individual workers' participation, and no process in place to obtain it.

When a regulatory investigation or legal action follows a workplace incident, that gap becomes the story.

Why Insurance Does Not Solve This Problem

When facing regulatory or legal action, many organizations turn to insurance protection as a backstop. It is worth understanding what insurance does and does not cover.

Insurance policies do not cover bad faith or gross negligence. The argument that company leaders have demonstrated gross negligence rests on the definition established in Hart v. Kline (1941): gross negligence as an indifference to a legal duty of care. An organization that provided training access without any mechanism to verify who completed it, or whether they engaged with it, may find that argument difficult to counter.

A completion record that cannot confirm identity or participation is not a defense. It is evidence of the gap.

What Verified Internal Training Looks Like

Integrity Advocate works with organizations to close that gap by verifying the identity and confirmed participation of internal personnel in every training session. The result is a record that demonstrates not just that training was accessed, but that the right person completed it and was present throughout.

This eliminates the exposure that comes from unverifiable training records in regulatory investigations, legal proceedings, and insurance disputes.

As one client senior leader put it: "How we deliver information to our personnel is indicative of the importance of that information to them."

The way an organization approaches training verification sends a signal about how seriously it takes what it is training people to do. For compliance training, safety training, and any instruction with regulatory or legal weight, that signal matters.

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Training Records Are Only as Good as What They Can Prove
Integrity Advocate verifies the identity and participation of every person completing internal training, giving your organization a documented record that holds up to regulatory and legal scrutiny, not just proof that a course was accessed.

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Frequently asked questions

Find answers to the most commonly asked questions from our clients.

A completion record confirms that a training course was accessed and finished. It does not confirm who accessed it, whether the person on record was the one who completed it, or whether they engaged with the content rather than clicking through. In regulatory investigations and legal proceedings, the distinction between training accessed and training completed by a verified, participating individual is significant.

The Canadian Public Accountability Board investigated PricewaterhouseCoopers and assessed fines of over one million Canadian dollars after finding that junior staff, managers, directors, and partners shared answers to internal training courses on auditing, accounting, and professional independence. The regulator found that PwC failed to establish policies and procedures providing reasonable assurance that training was being completed as intended.

Most regulators do not specify how training must be delivered or verified. They specify the outcome: that the workforce is trained. The assumption that providing access to online training satisfies that outcome is where organizations create compliance risk. Without a mechanism to verify who completed training and whether they participated, organizations may be unable to demonstrate the required outcome in an investigation.

Insurance policies generally do not cover bad faith or gross negligence. Organizations that provided training access without any mechanism to verify identity or participation may face arguments that they demonstrated indifference to a legal duty of care, which is the standard for gross negligence established in Hart v. Kline (1941). In that scenario, insurance protection may not apply.