Assumptions: A Major Compliance Killer (OPINION)
In my many years working as a compliance administrator for a major education company, I learned a few things about compliance roadblocks. Interestingly, the issues that create the most problems aren’t always what we might think they’d be.
While some may assume that simple disregard of rules and regulations is the biggest problem in keeping your business in compliance, this often isn’t the case. While some people do ignore guidelines, they either shape up quickly or don’t last long in business. A far more serious problem, and one that is not so easy to manage, is the habit of making assumptions.
There are two reasons why making assumptions presents such a problem in the area of compliance.
The first is that all of us have this habit. It’s just not possible to get through the day without making a decision based on what we think we already know. What good business people learn, however, is to discern when it is OK to assume and when it’s necessary to verify knowledge before taking action.
The second is it’s easier to assume than it is to verify. Verification takes work and also requires us to admit that we don’t have all the answers. Some of us are uncomfortable letting people know that we might be ignorant or mistaken, and most of us don’t like having to do extra work.
When we are given a list of rules, laws or regulations, it’s our responsibility to make sure that we not only comply with these directives but that we understand them. This is true even when the organization, agency or business that issues the directives hasn’t done a very good job in communicating them.
Here are some things I learned from my years in compliance that can help you avoid making assumptions and learn how to get, and verify, the information that you need.
Start your research early. You are more likely to fall into the habit of making assumptions if you are feeling a sense of urgency.
Learn to identify the assumption-making process. There’s an easy way to do it. Before making a statement or writing down a directive, ask yourself an important question: “How do I know this?”
If you find yourself thinking, “I know this because another company/agency has the same policy,” or “I know this because I heard someone say it once,” or “I know this because it just makes the most sense,” you are making assumptions. Stop what you are doing and verify your information.
A good practice is to find multiple references for business research. (I always required a minimum of three.)
For example, if you are researching regulations for a product or service, check for the regulation on multiple government and industry organization websites. If you notice discrepancies, it may be that the regulation has changed, and this will require more thorough research on your part.
Be wary of information that you get from other people in your industry. Given the human tendency toward making assumptions, even experienced professionals can be sources of misinformation. If someone you respect does give you information that contradicts what you’ve heard in the past, do some research and verify.
Learn to resist pressure from colleagues and clients who want you to give them a specific answer. There will be times when others will want you to give them a specific answer on a compliance issue. They may even do some research on their own and come to you with what they’ve learned in hopes of persuading you to greenlight a project or policy.
Ask about their sources and verify the information, just as you would do with information provided by an industry expert.
As a compliance leader, you have the responsibility to examine thoroughly some of your most basic human tendencies, which include making assumptions. Don’t be surprised, after you get some practice in doing this, that your ability to think logically and clearly has improved. Accept it as a welcome side effect of learning to be the best compliance professional that you can be.
Lainie Petersen previously served as a senior compliance administrator for a large educational company and is now editor of Walmart News Now.