As a Compliance Professional, one of the worst feelings you get is when the your Manager asks for evidence and you can’t find it because it's not where it should be. It is worse when the External Auditor asks the same question and your evidence is missing.
It has happened to all of us.
We all put off the activity of filing evidence, whether manually or electronically, and say to ourselves "I’ll do it later". The issues is, later never really comes along unless we have a pandemic.
What could the Auditor be thinking when they ask for evidence and it can’t be found quickly. They may to start looking a bit harder to find evidence of a poorly-run system.
This blog comes from an ongoing series that originated from "26 Ideas for Working from Home for Compliance Professionals".
Why is this Happening?
In today’s world of automation why is this still happening?
The answer could be one of the following:
- Saving data to the company’s server that everyone has access too.
- Poor storage and file tree layout with no company hierarchy.
- A Dropbox folder without enough space.
- Poor processes that produce too much information that is not required or shouldn’t be collected to start with.
- Filing duplicate data in multiple locations.
How Do You Improve the Collection of Evidence
So how can we reduce these effects when you are filing your compliance evidence?
- Design your processes so that they don't create files that have little value. For example, Take-5 forms are typically not analysed after filing (so why keep them?)
- Ask "what’s the value of the record?" For example, every time someone wants to add another form, ask "can you get the data from somewhere else?"
- Constantly question the value of data:
- What do we do with it?
- Does it help improve the company performance?
- If it doesn’t, it should be treated as waste and be removed.
- Look at existing processes that collect the data and evidence. For example, PLC’s and data loggers collect data and therefore you they don’t need a form to capture the same information.
- Remove duplication of the same evidence
- Integrate some of your forms. Fewer forms means less filing.
- Ensure your system has no waste built into it.
- Use online Software like Mango
How Do You Ensure Your Evidence is Easy to Access?
Making sure your evidence is accessible, readable and available takes time and discipline.
The first job is to remove waste in your systems. Systematically look through each process and see where the evidence is kept. If you spot waste then remove it immediately.
The second job is to check to make it accessible to the right people. If it's electronic check the access rights. If it's paper-based check to see who has access to the files (or filing cabinet). Once again remove waste. If there are old files that don't add value or are not required then bin them or archive them.
The next job is to investigate whether you can use online software that manages both the process and the evidence capture. This saves a large amount of time and reduces waste to a minimum.
Use this pandemic time wisely and make sure you are "audit ready".