Accountability and Consistency in Policy Development

In my experience, policy management processes are in disarray when operating autonomously, introducing risk in today’s complex, dynamic, and distributed business environment. The typical organization lacks a structured means of policy development and governance with an inconsistent maze of templates and processes. Inconsistency in policy management means processes, partners, employees, and systems that behave like leaves blowing in the wind. Organizations struggle with policies that are out-of-date, ineffective, and not aligned to business needs. Policy inconsistency opens the doors of liability, as an organization may be held accountable for policy that is not appropriate or complied with.

Organizations require a consistent governance process to develop and maintain policies and procedures. Policies articulate culture, they establish a duty of care, define expectations for behavior, and establish how the organization is going to comply with obligations. Accountability in policy governance is made possible by three policy governance functions:

  1. Policy Lifecycle Management. Policy Lifecycle Management is the process of managing and maintaining policies throughout their effective use within the organization. Implementation of Policy Lifecycle Management requires process and technology that is rich in content, workflow, process, and task management with a robust audit trail.
  2. Policy Management Committee. The Policy Management Committee governs the oversight and guidance of policies to ensure policy collaboration across the enterprise and provide the structure and connective tissue to coordinate and drive consistency. It is comprised of team members that represent the best interest and expertise of the different parts of the organization.
  3. Policy Manager. An individual should be assigned to the role of Policy Manager to assure accountability across the policy lifecycle to the standards, style, and process defined by the Policy Management Committee.

Critical to the success of policy governance is a “policy on writing policies” supported by a policy style guide and templates. Organizations are not positioned to drive desired behaviors or enforce accountability if policies are not consistent. Policy writing that is wordy and confusing is damaging to the corporate image and costs time and money. Every organization should have a structure in place to provide for clear and consistent policies. A significant shortcoming in policy management is the failure to define a policy style guide. A style guide for policies defines standardized:

  • Taxonomy. Policies are to have a logical relationship to each other following a hierarchical categorization taxonomy.
  • Format. Policies are to have a consistent look and feel. Anyone should be able to see a policy and recognize that it is a corporate policy by the consistent format.
  • Structure. Related to format, policies are to have a consistent structured arrangement of the headings/sections.
  • Language. Policies are to have consistent language. Good policies are written in the active voice and easy to read.
  • Definitions. Terms used in policies are to be used consistently across the organization with a common understanding of what they mean.
  • Process. The style guide should outline roles and responsibilities for writing, editing, and approving policies.

Policy lifecycle management that addresses accountability brings integrity and value to policy management. It provides accountability to policy management processes that are often scattered across the organization. It enables policy management to work in harmony across organization functions delivering efficiency, effectiveness, and agility. Well-governed and written policies aid in improving performance, producing predicable outcomes, mitigate compliance risk, and avoid incidents and loss.

I look forward to hearing your thoughts on the policy development and approval process . . .

This post is part of a broader roundtable and GRC Policy Illustration that was published by Compliance Week and hosted by OCEG.  The full piece can be accessed at:  Policy Development and Approval

There is also an webinar on this topic and illustration on October 4, 2012.

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