GUIDING effectiveness

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To be effective, Ethics & Compliance and Data Privacy programs need to be risk based. The U.S. Department of Justice explicitly states that the starting point for evaluating whether a program is well designed is to look at how the company has identified, assessed, and defined its risk profile; and the degree to which the program devotes appropriate scrutiny and resources to the spectrum of risks.

We can advise on Risk Assessment Strategy or help you design and execute your risk assessment and develop your mitigation strategy.

How confident do you feel about your program's direction, resourcing and governance?  Has the program developed in an intentional way, or has it added components and processes in reaction to critical events?  Are the program and oversight committee charters in good standing? 

We can support your efforts to enhance program strategy and structure while reinforcing accountability for process management and risk oversight. 

Keeping policies organized and current is a frequent pain point for companies, especially in a dynamic risk environment. Software vendors can help you manage workflow and disseminate policies; but typically, they do not have the expertise to advise on rationalizing your policy portfolio or optimizing content for risk coverage or readability.

We can advise you on policy simplification and rationalization, as well as helping you identify your use cases relevant to policy management vendor selection. We can assist with a tactical review of targeted policies and, as needed, prepare you for a more strategic transformation. 

Whether you are trying to enhance and scale an immature program or striving to keep up with leading practices, periodic, systematic evaluation is key. Definitions of program effectiveness have evolved significantly in the face of numerous factors: 

• Increased complexity of the risk landscape.
• Acceleration of data creation and the challenges of protecting it.
• Role of technology and digital media in scaling impact, both positive and negative.  
• Increased sophistication of regulatory and enforcement agencies.
• Heightened appreciation of the role of culture in mitigating or exacerbating risk.

We can support your continuous improvement efforts with a program "Health Check" or a comprehensive evaluation of program design, implementation and effectiveness and strategy reboot.