Control 1.12: Training and Awareness Program — Verification & Testing
Test cases and evidence collection for validating the training and awareness program.
Test Cases
Test 1: Training Content Completeness
- Objective: Verify training content covers all required governance topics
- Steps:
- Review all training module content against the governance requirements checklist
- Verify modules cover: acceptable use, data governance, sensitive data handling, reporting obligations
- Confirm FSI-specific content addresses supervisory requirements and regulatory context
- Check that content is current with latest Copilot features and governance policies
- Expected Result: Training content covers all required governance topics
- Evidence: Content review checklist with sign-off from compliance team
Test 2: Training Completion Rates
- Objective: Verify training completion meets target thresholds before each deployment wave
- Steps:
- Run PowerShell Script 1 to generate compliance report
- Verify completion rate exceeds 95% for the current deployment wave
- Identify any departments below the threshold
- Confirm non-compliant users have not yet been granted Copilot access
- Expected Result: 95% or higher completion rate for active deployment waves
- Evidence: Training compliance report with department breakdown
Test 3: Knowledge Retention Verification
- Objective: Validate that training effectively transfers governance knowledge
- Steps:
- Administer a brief post-training assessment to a sample of 20 users
- Include questions on acceptable use, data governance, and reporting procedures
- Verify average score exceeds 80%
- Identify common knowledge gaps for targeted reinforcement
- Expected Result: Average assessment score of 80% or higher
- Evidence: Assessment results and analysis
Test 4: Awareness Communication Delivery
- Objective: Confirm ongoing awareness communications are delivered and read
- Steps:
- Review the awareness communication calendar for the past quarter
- Verify all planned communications were sent on schedule
- Check email open rates or Teams message engagement metrics
- Survey a sample of users to verify they recall recent awareness content
- Expected Result: All planned communications delivered; engagement rate above 50%
- Evidence: Communication delivery records and engagement metrics
Evidence Collection
| Evidence Item |
Format |
Storage Location |
Retention |
| Training content review checklist |
PDF |
Compliance evidence repository |
7 years |
| Training completion reports |
CSV |
Compliance evidence repository |
7 years |
| Post-training assessment results |
PDF |
Compliance evidence repository |
7 years |
| Communication delivery records |
PDF/CSV |
Compliance evidence repository |
7 years |
Compliance Mapping
| Regulation |
Requirement |
How This Control Supports It |
| FINRA Rule 3110 |
Supervisory training |
Copilot governance training supports compliance with supervisory training obligations |
| SEC Regulation S-P |
Employee awareness |
Security awareness training helps meet employee awareness requirements |
| GLBA Safeguards Rule |
Employee training |
Data governance training supports compliance with safeguards training requirements |
| NIST AI RMF |
GOVERN 4.2 — AI training |
AI-specific training supports compliance with AI governance training requirements |