We are implementing an LMS (purchased Plateau) and have run into a situation we are trying to address. Plateau’s system provides managers with the ability to see their employee’s training records, grades, as well as general employee data. The challenge is that different European countries have laws limiting a manager’s access/view to employee training records and other employee data. Has anyone implemented an LMS and had to deal with this issue? If so…
1. What approach did you take?
2. Was it a problem for other training organizations (outside of HR) also saw this data?
3. Could the manager see pass/fail statuses? Exam grades? Employee’s sex?
4. Anything we should be wary of?

We’re currently debating turning off the manager’s access to their employees, Safe Harbor, and/or amending the employment contracts. Any advise you can give would be great.

I had a similar situation working at a global company based in the US. While leading a project in selecting a LMS, I included as part of the selection criteria that the LMS addressed global and localized rules. A few LMS I was looking at supported "domains". This allowed us to create a hierarchy and apply rules at certain levels of the hierarchy that would be inherited by its children. In this way we could apply rules to a domain (such as France) and we could apply access rights within the domain and control who had access to what. So managers in the US could see their direct reports pass/fail status, but managers in France could not.

I worked with our legal department on the international laws associated with training and development in order to define the criteria on how it should be managed independent on whether we used a LMS or not, and simply used it to create the business requirements of the LMS for the RFP.

Work for a VERY large multinational financial org with the same issue (different system) and one prior to that (yet another system) with reporting restrictions that applied to specific regions.

The solution, if available in Plateau, is as Pat states. The Admins/SuperAdmins of your LMS need to be assigned to regions that limit their rights accordingly. If the LMS is tied to your HRIS, all of the manager rules/etc. should be appropriately applied.

Most systems offer this "domain" or "subportal" capability.