Learning Management System

What a learning management system is

A learning management system (نظام إدارة التعلم), abbreviated LMS, is a system that hosts training content and records who completed it and when. It also manages the enrolment of employees on learning paths and tracks their progress along those paths.

What a learning management system does

The functions of a learning management system are these:

• Keeping the content. It holds the training content in one place, instead of in separate files kept by each of the trainers who prepared it.
• Recording completion. It records each completion together with its date. In practice, that dated record is the most important thing a learning management system produces.
• Assigning mandatory paths. It assigns compulsory learning paths to groups of employees, such as a path on occupational health and safety or a path on compliance policies.
• Alerts. It sends an alert when the date of a training session is approaching, or when a certificate is about to expire.
• Reports. It produces reports on completion rates and on the employees who have fallen behind them.

The problem a learning management system actually solves

The problem that a learning management system solves is a problem of proof before it is a problem of instruction. It concerns being able to show that training took place, and it comes before any question about the training itself.

Consider the question: who was trained on this policy, and when? Without a system, answering it requires a search through scattered records, and those records may not exist at all.

A learning management system makes the same question answerable in a moment, because each completion has already been recorded with its date. That matters in mandatory training in particular, where the question being asked is precisely who completed a required path, and on what date.

What a learning management system does not do

A learning management system measures completion, not learning. Its record shows that an employee reached the end of a path. It does not show what the employee learned on the way.

A high completion rate therefore does not mean that the effect of the training has carried over into the work. Measuring that effect needs an indicator from outside the system, such as a fall in a particular kind of error after the training has been given. The system records that the training was completed; whether the error became less frequent afterwards is something it does not record.

Relying on the completion rate alone as the indicator of training measures the activity, not its result.

The data side of a learning management system

Training records are personal data concerning the employee, as the contents of the employee file are, and they can include test results and failed attempts. The way they are handled is a question of employee data privacy: it falls under the provisions of the Personal Data Protection Law (نظام حماية البيانات الشخصية) in the Kingdom, issued by Royal Decree M/19 of 9/2/1443H and amended by Royal Decree M/148 of 5/9/1444H.

Article 2(1) of the Personal Data Protection Law applies the law to any processing, by any means, of personal data relating to individuals that takes place in the Kingdom. Article 1 of the Personal Data Protection Law defines personal data as any data, whatever its source or form, that identifies an individual specifically or makes it possible to identify them directly or indirectly. The same Article 1 of the Personal Data Protection Law defines the controller as the party that determines the purpose of processing personal data and the manner of that processing. An employer keeping training records on its employees is in that position. Article 1 of the Personal Data Protection Law also defines processing, and the operations it lists include collecting, recording, storing, retrieving, using, disclosing and destroying. Recording completions and producing reports on them are therefore processing within the meaning of the Personal Data Protection Law.

Among the provisions of that law are the following two duties of the controller.

• Specifying the purpose of collection. Four articles set it out. Article 10 of the Personal Data Protection Law permits personal data to be processed only to achieve the purpose for which it was collected, subject to the seven exceptions that article lists. Article 11(1) of the Personal Data Protection Law requires the purpose of collecting personal data to relate directly to the purposes of the controller and not to conflict with any provision established in law. Article 12 of the Personal Data Protection Law requires the controller to adopt a privacy policy, available before collection, that specifies the purpose of collection among its other elements. Article 13(2) of the Personal Data Protection Law requires that, where personal data is collected directly from the person it concerns, that person be told the purpose of collecting it.
• Limiting the data to the minimum that serves that purpose. It is set by Article 11(3) of the Personal Data Protection Law, which requires the content of personal data to be appropriate and confined to the minimum necessary to achieve the purpose of collecting it, while avoiding content that would lead to the person being identified specifically once that purpose has been achieved, and which leaves the controls needed for that to the Implementing Regulations of the Law.

Alongside those duties, the disciplined practice is for access to training records to be limited to those who need it for a declared purpose, rather than open to every manager in the organisation. That is a practice in how a learning management system is set up. It is not one of the statutory duties named above.

What comes before buying a learning management system

A learning management system serves a training plan that already exists. It does not create that plan.

If a training needs analysis has not come before it, the system turns into a library of content that serves no specific gap.

The practical order is therefore this: identify the gap first, then decide on the way in which the gap is to be addressed, and only then choose a tool that manages that response. The order does not run the other way, from the tool to the gap.

This is an explanation of the concept and of the statutory provisions cited, not legal advice.