One of the easiest questions to answer right? Go on, What’s Compliance?
If I was asked this a few years ago I would have responded completely different to how I would respond today. This isn’t because compliance has changed or because peoples desire to be seen to be doing more has changed, its just because my understanding of things has changed, my knowledge base has improved. The question I think I would struggle more with is whether we ‘Manage’ compliance or ‘Monitor’ it. I mean how can you do either if you don’t understand the first question.
Compliance – The act of conforming.
How do we conform to something when its managed by someone when everyone’s views and opinions are different. Does that mean compliance and the art of conforming is scaleable based on the person you’re working for? Everybody is different so that means compliance is always different. If I work for a leader who demonstrates a laissez-faire management style does that mean compliance is easier than if I was working for an autocratic leader?
One of the best responses I had when asking this question was this;
‘Compliance is the overarching term used to describe research, assurance, verification and validation when used as tools to assess a piece of work or product, regardless of size’
It’s really important to understand each section of the answer above so that you fully understand why certain milestones are aimed for.
Research – You wouldn’t commission work to install fancy lights to an outdoor swimming complex at a Centre Parcs if you knew the day it was planned in there was going to be a thunderstorm!!
Most people do this without knowing but the key is to formalise it and make it a routine and not a game of chance.
Assurance – Is it enough to accept I am a helicopter pilot because I can pat my head whilst rubbing my stomach at the same time!!??
Assurance is such a strong word and provides a level of protection against something happening. We all pay for insurance but the whole principle of insurance is that we get back or were covered when something happens. Assurance is about trying to find the best way to prevent that in the first place. Being proactive to risk rather than reactive.
Verification (Certifications) – Its simple, we don’t trust people because over time we’ve learnt to accept that people sometimes don’t do what they say they’re going to.
Data is really important when managing work and the best place to get data from is the workforce. Being able to manage and understand trends in certificates and data helps you improve on areas requiring it and push a little further in those that don’t.
Validation (Evaluation) – If I had to put an American Flag somewhere and my life depended on it not being removed from the ground. I wouldn’t put it in Hyde Park, London. I’d probably find a way to get it next to Armstrongs Flag on the moon.
A great quote in Asset Management is the lifecycle management via a ‘Lust to Dust’ process. Accepting that compliance starts when you have the thought rather than the physical asset will put you in good stead to evaluate what you want to achieve from inception. Not only that, the evaluation process is about ensuring the task/job last for the duration you specify. Everything has an end date, that’s life, the key is accurately predicting it with data that’s not been plucked out of thin air.
So taking the definition above its clear we have a statement that should help any person or organisation understand the simple first steps they need to do to start the process of compliance. So when you’re starting a project or tasks with managing anything, always remember R.A.C.E.
Now that we have the starting point documented what should we do during the works and afterwards. The process has to be continuous and easy to understand. There’s a real need to interject certain checks in the process to ensure you’re on track. There’s a saying that if you don’t measure something, how do you know if it’s getting better or worse. We need to find systemic processes that are again easy to manage and gives us measured data, that data should then provide further milestones that have been achieved or need monitoring.
The next major part of compliance is something I covered in a Home Truths in Social Housing blog back in Jan 2017. It has everything to do with people knowing exactly where they stand in terms of decisions and accountability.
To get a great understanding of what I am about to explain you should try and get hold of a Video that The Institute of Asset Management has produced called “The Asset Management Journey”.
When we consider compliance of a job we almost always find that we’re sat in front of the finance team first trying to justify something from a financial perspective. We answer questions like ‘but can we do 10% less?’ Or ‘can we slip this to next year?’. The issue here is two people whose end goals are completely different yet both their actions impact each others end goal, so they don’t want to back down.
Once you’ve firmly placed your sales hat on your head and managed to convince the finance team the budget is required. You have to then move onto the legal team whereby the original problem of two different end goals is back.
Ultimately the more teams you have to justify your decisions too, the more diluted the message gets. You have to appreciate that those teams will also talk and they won’t be able to convey the task in a technical way and so will dumb down the work meaning your hard work to define risk and cost is wasted.
It’s a difficult situation to be in.
How do we get by this and ensure compliance? We’ve carried out our initial R.A.C.E checks for the project but now we need to ensure trust in what you’ve done is achieved.
T – Trust
R – Respect
U – Understanding
T – Transparency
H – Honesty
So, as per my initial question, what is Compliance? My view today is that Compliance is a RACE towards TRUTH. Ultimately we have to use common sense when managing or monitoring compliance. This year it’s top of the agenda so maybe organisations should review the content of this article and see where it leads.