Closing the Loop Using Automation to Build a Better Compliance Program

Transcription

1 Closing the Loop Using Automation to Build a Better Compliance Program Automation: the act of using a control system ( apparatus ) to manage, command, direct or regulate the behavior of other devices or systems 1

2 To Cover Part 1: Identifying processes ripe for automation Part 2: Creating apparatus to get the information you want, the way that you want it Part 3: Measuring results and holding people accountable To invent, you need a good imagination and a pile of junk. -Thomas A. Edison 2

3 Part 1 Identifying Compliance Processes Ready for Automation What is an eligible compliance process? Characteristics of a (bad) process ready for automation Example 1: Templates Exercise: Have you considered? Part 1: Identification Defining a compliance process (for our purposes) Compliance team ownership Requires business-side input Used to reduce or identify compliance risk 3

4 Part 1: Identification Characteristics of a compliance process ready for automation Repetitive, time-consuming & annoying Inputs are open to interpretation Consequences for non-participation are absent or poorly defined Part 1: Identification Scenario: Information Requests Background s sent to business multiple times per day Good response rate, but quality of responses was inconsistent Treated business as partner, not as customer 4

5 Part 1: Identification Automation Solution: Templates within templates Goal Automation Solve Make it easier for business to understand request Make it easier for business to obtain information Increase scalability Requests are bucketed by type, with allowance for flexibility Pre-filled template-within-the-template for use by the business Standard choose-your-own adventure template with limited placeholders Part 1: Identification Exercise: Have you considered? Steps Find a partner or two Describe an annoying, manual compliance process that could be automated Partner asks, Have you considered [potential process improvement]? Automation Cheat-sheet Focus on setup Limit ambiguity Report, report, report Switch 5

6 Part 2 Building Apparatus to Get the Information You Want, the Way That You Want it Laying the groundwork Building the apparatus Example 2: Surveys Exercise: Open, Close If there is any one secret of success, it lies in the ability to see things from the other person s point of view as well as from your own -Henry Ford 6

7 Part 2: Creating the Apparatus Groundwork: Compliance as translation What are the requirements? What information do you need to assess compliance with these requirements? What business question will get you this information? Why do it this way? (customer focused vs requirement focused) Part 2: Creating the Apparatus Selecting a tool Standard Tech Tool Legacy Compliance Solution Repurposed Solution Custom Solution Word Excel SharePoint InfoPath Adobe Forms Survey tools Purpose-built platform Extensive modifications to existing (supported!) platform 7

8 Part 2: Creating the Apparatus Characteristics of an effective apparatus Inputs are in business language Asks as little as possible but as much as needed Elicits honest answers via limited choices Part 2: Creating the Apparatus Scenario: Surveys Background Needed to evaluate whether we were subject to a complex regulatory requirement Various ways of triggering the requirement Asking a large number of business partners Limited resources 8

9 Part 2: Creating the Apparatus Automation Solution: InfoPath survey forms Goal Automation Solve Make it easy for business to understand request Only get details on questions relevant to the team Minimize contact with the business Increase scalability Pre-survey exercise to translate requirements into business practices Conditional do you do this? questions for each type of triggering activity Detailed examples Closed-ended questions Comment fields Assigned via Sharepoint platform; organized responses as library data Part 2: Creating the Apparatus Exercise: Open, Close Steps Look at the card that was on your seat Find a partner or two Read an open question Partner closes the question Automation Cheat-sheet How good is What are the your X program? elements of your X program? Do you do Y? Do you have Z under control? How often do you? How many times did Z happen last year? 9

10 Part 3 Measuring Results and Holding People Accountable Being the messenger without getting shot Example 3: Risk Assessments Manual processes that make automation work When you can do the common things of life in an uncommon way, you will command the attention of the world. -George Washington Carver 10

11 Part 3: Results & Accountability The big challenge driving compliant behavior High touch does not mean high impact Soft touch consistently applied cultural change Creative reporting: the best tool in the compliance professional s toolkit Part 3: Results & Accountability Get buy-in Create outputs One-to-one Business input to compliance output Many-to-one Business story to compliance output (solution-driven) Ask for feedback, and adjust accordingly 11

12 Part 3: Results & Accountability The bigger challenge measuring (& validating) impact Discrete value vs change over time The year-zero problem Closing the feedback loop Adding, subtracting and changing inputs Part 3: Results & Accountability Scenario: Risk Assessments Background Annual assessment recommended by regulators Regional processes are inconsistent (if lucky) or non-existent English not everyone s first language Limited resources for travel & interviews 12

13 Part 3: Results & Accountability Solution: Automated Risk Assessment Goal Automation Solve Consistent methodology Questionnaire is the same for all users Repeatable process Uniform upward reporting Benchmark progress Low time impact (no report drafting) After baseline, confirm or change Report format is fixed Validation mechanisms can be built in All outputs turn into data points Same data points over time allow for meaningful stories Part 3: Results & Accountability Tools to increase visibility and drive participation Three lines of defense model Committee-level reporting Compliance as a success metric 13

14 Questions? 14