Business Core · Compliance · Module

Controls

The mechanisms that make compliance happen — built into how work is done, rather than checked afterwards.

The idea

How it works

A control built into the process happens by default; one that depends on remembering happens when people are not busy. The first survives pressure, the second is exactly what fails when it matters.

Controls must produce evidence as a by-product of operating. A control with no trace cannot be demonstrated to have worked, which for regulatory purposes is close to it not having worked.

Working with it

In practice

  1. 01

    Prefer preventive to detective

    A system that will not accept the wrong entry beats a report that finds it next month.

  2. 02

    Name an owner per control

    Someone accountable for it operating, not just for the policy existing.

  3. 03

    Generate evidence automatically

    Evidence produced by operating the control, rather than assembled before an audit.

  4. 04

    Separate incompatible duties

    The person who requests should not be the person who approves. Small organisations need a compensating control instead.

One level in

The components of controls

A component is something that exists afterwards which did not exist before — a deliverable or a mechanism, not an intention.

  1. The control set

    Each control, what it addresses, and whether it prevents or detects.

    Learn
  2. The control owner

    Who is accountable for the control operating.

    Learn
  3. The evidence trail

    What the control produces as proof that it ran.

    Learn

A control that depends on remembering fails exactly when the pressure is on. Build it into the process.