Compliance Conversations: How often should the Context of the Organisation be reviewed?

Posted by Craig Thornton

In this video, Peter Rogers from Mango discusses Context of the Organisation as part of the Compliance Conversation series.

We have gathered compliance consultants from around the world to give some insights into the ISO requirement, clause 4 "Context of the Organisation".

The question we answer in this conversation is "How often should the "Context of the Organisation" be reviewed and who should be involved in that review?

Check out the video here:

 

Video Transcription

How often should you review the context of the organisation, and who should be part of that review?

 

Chris, FQM, United Kingdom

I don't think there's a one fit for all here.

If you are an organisation and you do an analysis and understand you're an organisation that is a hungry, growing organisation, that is acquiring other businesses, that is evolving into providing other products and services, then I actually believe that it's something that should be reviewed fairly regularly.

The most important factor is, are we bringing in any additional weaknesses into the context of what our business does?

If you are that type of business, a monthly or quarterly review is required. The review may have to involve quite a number of people. For example, if you're acquiring new businesses, you may have to involve legal teams, and those people that you consult with, to advise you on the companies you're buying, so that the due diligence is done correctly, and there's no additional weaknesses that you're not aware of.

However, if you're a business and the operation that you work in is very static, you sell this widget to these types of companies, and that does not change and your supply chain is not changing, then that may be something you just have a quick review of on an annual basis.

I would put a caveat into that. In the situation of where we're at today, 2020 going into 2021, (and COVID-19 is with us) there is no way that any business almost on the planet that can say that COVID-19 is not having an impact on them. Even if it's not impacting within their four walls, and they're still operating as they were, do they really know that their supply chain is as solid as they thought it was? Therefore, I think, you will probably find a number of companies, are reviewing these types of things, on a week by week, month by month basis, to understand

    • Is lock down having an impact on us?
    • Could it have an impact on our supply chain as we go forward?

We can also bring into that, in the UK, Brexit. That changes legal structures and legal operating standards. There's a lot of companies that need to be considering that and have been for quite some time.

Do they call it a ‘meeting to review the context of the organisation?’ No, but I don't think they have to, I think they just have to be able to demonstrate what they're doing to understand what these potential external issues are that can impact on their business.

Ultimately, if they can record that, maybe in the management review on an annual basis to say, these are things that they look at regularly, because of the issues to do with Brexit, or COVID, or other factors, then I think that would be sufficient.

John, Many Caps, New Zealand

It depends.

If you're in a business that has got a really stable legal background and that your competition doesn’t change very much, and the technology never changes very much, you might only need to review annually, that may be enough.

But if you've got a business where you have maybe high staff turnover, or you have really tough competition, where technology is moving really fast, or the rules regulations governing your business change a lot, you probably want to review it more often.

You make want to double check it quarterly, they don't have to be big reviews, don't have to be days and days, it can be half an hour or an hour and get through it like that.

It's about what's right for your business. At a minimum, every year, but you probably want to do it every six months.

Ben, Total Management and Training, Australia

The review should happen during the normal Business Management Review meetings.

But to be honest, the results of identifying the context of an organisation actually have lots of benefit around things like business planning and strategic direction, because you're identifying those issues, and you're also identifying potential positives and places that you might want to go. It's always a good thing to do that throughout the year, even when you may not be doing the reviews.

However, as a minimum I would usually recommend you're doing them with the normal business review meetings.

Participation will vary depending on the organisations, but it should really include those people you identify when you're looking at those internal and external stakeholders. The more information you can get from them when you're doing your reviews, the better the information that's going to come out of those review meetings and therefore, the better the system can be, based on those decisions that you're making.

Jodie, Penarth Management, United Kingdom

The context should be reviewed at least annually.

Ideally, this will be done by internal auditors talking to senior management and the understanding if there have been any key changes within the organisation,

Nicholas, SRM, South Africa

We've got two different ways that we look at identifying and reviewing the context of the organisation.

We have a set mandate with some of our clients that say;

    1. We review the context of the organisation annually at the Management Review meeting.

There the various different role players that will be involved in as a crosscut of the organisation all the way from top management, supervisors, management, all the way down to workers and their representatives. So, that would be at the fixed Management Review.

However, I do believe that the context of the organisation, should have some triggers written into your processes for ad hoc review.

    1. If there are significant incidents, significant legal changes, significant changes in resources, new acquisitions to the business.

I believe that those should be ad hoc triggers, to the review of the context of the organisation that again, should be done by a crosscut of the organisation, from representatives from the shop floor, all the way up to top management.

 Mark, Business Basics, Australia

Context should be casually reviewed consistently by most members of the organisation. If something happens to pop up, that will massively shift the direction, the company's in, such as COVID, which is a really good example, you need to go and spark a formal review of that process.

However, the overall context should be formally reviewed, maybe once a year.

The way I like to think about it is, a ship traveling from Sydney to Copenhagen, you're not going to review whether it's going to Copenhagen on a daily basis, you're going to review,

    • whether it goes around storms,
    • whether it follows this channel, goes around that channel,

However, the general view and the goal is still going to be, to get to Copenhagen.

The context is that sort of high level - as to what we're about to achieve, therefore by changing it and reviewing it every two to three weeks, it just creates confusion throughout the business.

Michael, Momentum Safety and Ergonomics

I'd like to be involved if I was the quality or health and safety person, as obviously, you're driving these processes happen, but the decisions aren't being made by you, it's management that first and foremost must be involved. They are the ones who run the business and a lot of these impacts are going to affect the business and their role in that personally.

But as I said with my answer to the previous question, if you want to make it work really well, why not get the others involved?

Work down your line to supervisory and workers at things like toolbox meetings, and the question you ask is;

"These are some of the things that we've thought about previously. What else? What other things? What's changing about the environment that we're working in?"

In the Gold Coast, a couple years back, we had the Commonwealth Games, and that had a huge impact on local businesses. Some positive, some negative. But it had to consider things like transportation.

Nowadays, every business must be thinking about, COVID and the potential for other sort of pandemic, epidemic events as well.

 

Takeaways
  1. Review as often as necessary, especially if significant changes or events occur, both internally or externally, that may affect your business.
  2. Involve as many people as necessary from top management through to representatives of the employees.
  3. Record the reviews so that you can demonstrate that there is an understanding of any potential issues that can have an impact on your business.

Tags: Compliance, Compliance Conversations, Context of the Organisation