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Over the past decade or so, corporate compliance initiatives have received a considerable amount of attention and as a result have matured considerably. However, the approach to collecting, tracking, monitoring, reporting and benchmarking data is still a bit behind the times (think massive Excel files and Sharepoint sites). This not only creates inefficiencies, but greatly impacts the effectiveness of the compliance program. In this SlideShare, we explore the imperative for compliance program data and how can directly (and positively!) impact the effectiveness of a compliance program.
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WHAT THE DOCTOR ORDERED
The Imperative for Data-Driven Compliance
©2014 Convercent. All rights reserved.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Here’s what vital stats your doctor records when you visit her:
ü Height, weight and body mass index (BMI)
ü Blood pressure
ü Cholesterol
ü Blood sugar
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
What makes that data USEFUL?
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
1. It’s measurable
2. It’s verifiable
3. It’s contextual
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
If it’s MEASURABLE, you can:
• See changes over time
• Compare against baseline for
your age and gender
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
When it’s VERIFIABLE, you have:
• Records meticulously maintained over time
• Reliable, historical data to benchmark against
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
CONTEXTUAL data allows you to see how:
• Imbalances in one area may explain red flags in another
• Stats converge to paint a complete picture
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
When you can measure and verify data, in context, you can: • Quickly identify areas of concern • Draw logical conclusions and make informed decisions
based on the big picture • Be confident in the accuracy and completeness of the data
you’re basing your decision on
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
So why is compliance any different?
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Pssst…it shouldn’t be!
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Today, compliance officers can use technology to:
• Record incidents from the hotline, web and in-person reports
• Track investigations
• Manage policies and acknowledgments
• Administer and track training
• Conduct risk assessments
• Manage disclosures and surveys
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
But…that still doesn’t give us an accurate picture of compliance effectiveness
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
You need an effective strategy that outlines what to measure, how to
measure it and to facilitate improvements once you have the critical
data in hand
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
You need an effective strategy that outlines what to measure, how to
measure it and to facilitate improvements once you have the critical
data in hand
• How do you know what you’re doing is working?
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
You need an effective strategy that outlines what to measure, how to
measure it and to facilitate improvements once you have the critical
data in hand
• How do you know what you’re doing is working?
• How do you validate improvements in your program?
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
You need an effective strategy that outlines what to measure, how to
measure it and to facilitate improvements once you have the critical
data in hand
• How do you know what you’re doing is working?
• How do you validate improvements in your program?
• How do you show a good-faith implementation of your program?
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Like your personal health,
compliance data—in order to be
useful—needs to be:
1. Measurable
2. Verifiable
3. Contextual
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
1
Measure. Everything.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
“You can’t manage what you can’t measure”
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Quantitative data provides: • Consistency and objectivity • Easy measurement of progress over time • Quick assessment of weak spots or problem areas
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Quantitative data allows for benchmarking. Against your historical results. Against your industry peers. And against industry best practices.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Quantitative data allows for benchmarking. Against your historical results. Against your industry peers. And against industry best practices.
(this is extremely important: th
e regulators expect
you to benchmark your program’s effective
ness)
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Effective benchmarking helps you continuously improve your program.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Effective benchmarking helps you continuously improve your program.
(oh, yeah…the regulat
ors expect this, too!)
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
2
Make sure you can verify.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
• For your compliance team
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
• For your compliance team
• For your front-line managers
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
• For your compliance team
• For your front-line managers
• For your board
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
• For your compliance team
• For your front-line managers
• For your board
• For your auditors
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
• For your compliance team
• For your front-line managers
• For your board
• For your auditors
• …and for regulators (if and when they should ever ask)
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
It’s important that the data is accessible and reliable
• For your compliance team
• For your front-line managers
• For your board
• For your auditors
• …and for regulators (if and when they should ever ask)
(if anything ever goes
wrong, you’ll need a record
of your program initiatives
readily available)
…ask Morgan Stanley why this is important
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
3
The data needs context.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Your compliance initiatives are not standalone efforts.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Policies are written to address your risk areas.
Training and communications reinforce policies.
Hotline reports indicate gaps in training and policies.
Culture surveys show how effective your hotline is.
…and the list goes on
Your data needs to be just as connected. So that when you have a surge in discrimination claims, you can immediately focus on your discrimination
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
You should strive for a risk-based program and risk-based data. Your risk assessment should be the lens you evaluate your program data through. This will help you prioritize your efforts and resources to address your most critical risks.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
And there you have it.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
1. Measurable
2. Verifiable
3. Contextual
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Okay, we know this is easier said than done.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Because at the end of the day,
this is tough to verify.
Difficult to measure over time.
And it’s nearly impossible to
understand the context of
what you’re seeing. (not to mention it’s prone to human error and resource constraints)
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
That’s where technology comes in.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Technology facilitates the tracking, measuring, reporting and assessment of key compliance program metrics.
So that you can:
ü Identify, manage and mitigate key compliance risks
ü Enable effective oversight and monitoring by executives and directors
ü Easily assess and benchmark your program
ü Continuously improve your program
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Ultimately, you’ll provide your organization with an affirmative defense in the form of an
effective and measurable compliance program that preserves the financial and reputational
health of your organization.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
After all, isn’t that the point?
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
Ready to see how technology can enhance the effectiveness of your program? Let’s talk.
WHAT THE DOCTOR ORDERED: DATA-DRIVEN COMPLIANCE
©2014 Convercent. All rights reserved.
About Convercent Convercent’s solution operationalizes and integrates compliance functions across key compliance risk areas, enabling a cohesive approach to managing, mitigating and monitoring compliance risks. Pairing a refreshingly intuitive user interface with natively integrated reporting and analytics, Convercent’s compliance program management solution ultimately facilitates the efficient, good-faith application of an effective and defensible corporate compliance program that safeguards the financial and reputational health of your company. Learn more at convercent.com or contact us at 866.403.2713