Grace Wu de Plaza, CCEP and CIPP/US, Group Head of Ethics, Ferguson Enterprises LLC in Newport News, Virginia, USA
AT: You have had a very interesting career both inside and outside of compliance, and it’s far from a straight line, but it’s an intriguing one. Right after college, you worked in market research. In some ways, it’s very different from compliance, but I imagine a lot of the skills you picked up there have been useful in assessing culture. For example, what do you think makes for better surveys?
GW: If you had told me 20 years ago that I would use the data analytics skills from my market research days, I would not have believed you. There are different ways to assess culture, and sending a survey is an efficient and effective way to measure it. Having data is good; having data with demographic information, though, is better. While in market research, we collected both types of information. Collecting demographic information and combining it with transactional data is more powerful because it allows us to target communication and training to specific associate populations. It is important to remember that some associates hesitate to provide demographic information because they may be concerned that their answers may be traced back to them. For this reason, when requesting data, transparency is vital. For example, let associates know that data are reported in the aggregate if that is the case. With the increase in data protection laws in recent years, compliance and ethics professionals should partner with privacy counsel when working with associate data.
AT: What mistakes are easy to make when developing surveys designed to understand the culture and what associates are thinking?
GW: Words matter. How you phrase a statement directly affects the response. For this reason, prior to launching new surveys, it may be helpful to pilot the questions and seek feedback so that those responding to the survey are reading the statements the way they are intended to be read. Trust experts. If your company has communications, data analysts, or market researchers, seek their feedback. When developing surveys, I tend not to use scales that only consist of phrases; instead, I use a numeric scale. A numeric scale can show incremental improvements. And as mentioned before, always try to have demographic data (e.g., role, number of years with the company, department, geographic location) so your communication and training can be more targeted depending on the survey results. The ability to target training and communication is essential as the U.S. Department of Justice emphasized that one hallmark of a well-designed program is to have tailored training and communications.