OCEG Policy Management Illustrated Series Written policies are essential - but they are only effective if individuals are aware of them, committed to them, and expectations understood. In today’s legal climate, having an audit trail of when policies were communicated, when individuals were trained, and when individuals acknowledged their commitment and understanding of them is critical to defending the organization when faced with legal and regulatory matters. ESSENTIAL ELEMENTS OF A COMMUNICATIONS PLAN Why does it matter? AUDIENCE Write the communication and training plan to meet the unique needs of each target group. VERSION (DATE, TIME) QUESTIONS TO CONSIDER COMMUNICATION GOALS Define specific communication goals and strategies for distribution, certification and training for each policy. QUALITIES OF DEFENSIBLE AND EFFECTIVE COMMUNICATION AND TRAINING Are adequate resources in place? Does it adhere to the code of conduct? Is it timely? How do we measure success? Is it relevant? Will those with disabilities and differing language needs understand? What level of training and communication is appropriate? What records are necessary to show that training and communication took place? Align communication and training strategies with the corporate culture and Code of Conduct. Gain support of executives and management. INTERNAL STAKEHOLDERS Collaborate with and enlist the support of internal stakeholders across the business. MONITOR & REVIEW ALIGNMENT 4 5 6 7 8 Effective compliance programs can pinpoint, by individual, the version of a policy that was communicated and the communication activities surrounding that version. Communication plans should include how to ask questions about policies and request policy exceptions. Effective programs include ways to document, approve and periodically evaluate questions and exceptions in order to update policies and/or identify emerging risks. TRACKING ONE DISTRIBUTE TWO DISTRIBUTE & CERTIFY ACCESSIBILITY Decide on the metrics that will constitute 'success' for each phase of the communication process. 3 ! Do people understand? Assign the appropriate people, budget and other resources to ensure communication goals are met. MEASUREMENT 2 QUESTIONS & EXCEPTIONS RESOURCES Develop each policy and training program to be accessible, understandable and actionable by all groups regardless of education level, geography, culture, language, ethnic group or disability status. 1 The policy communications team is accountable for establishing and ensuring the success of the communication and training plans. DISTRIBUTE, CERTIFY & TRAIN 0 1 0 0 1 0 1 1 0 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0as the 1backbone 1Utilize0technology 0 and 0 to1implement 1 measure 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 of1 your 1policies1 and your 1the effectiveness 1 1 communication 1 1 1 1plans.1 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1 0 1 1 0 0 1 1 0 0 0 0 BENEFIT 0 0 0 0 0 0 0 0 1 0 OF 0 THE 1 0 1 0 1 TECHNOLOGY 0 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 1 1 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 TECH 0 1 0 0 1 0 1 0 1 0 1 1 0 1 0 1 0 1 DATA 0 1 0 0 1 1 0 1 1 0 1 0 1 0 1 0 0 1 1 1 1 1 1 1 1 1 1 1 1 0 1 0 1 0 1 0 1 0 1 0 0 0 0 1 0 0 1 0 0 0 0 1 0 0 0 1 0 0 1 1 0 0 1 1 0 0 1 1 0 1 1 1 0 0 0 1 0 0 0 1 1 1 0 1 1 1 0 1 1 0 0 1 0 0 0 1 0 0 1 1 1 0 1 1 0 0 1 1 0 1 1 1 0 0 0 1 0 0 0 1 1 1 0 1 1 1 0 1 1 0 0 1 0 0 0 1 0 0 1 1 0 THR EE 0 1 1 0 0 1 1 0 1 1 1 0 0 0 1 0 0 0 1 0 1 0 1 1 1 0 1 1 0 0 1 0 0 0 1 0 0 1 1 0 0 1 1 0 0 1 1 0 1 1 1 0 0 0 1 0 0 0 1 0 1 0 1 1 1 0 1 1 0 0 1 0 0 0 1 0 0 1 1 0 0 1 1 0 0 1 1 0 1 1 1 0 0 0 1 0 0 0 1 0 1 0 1 1 1 0 1 1 0 0 Integration Visibility Global Reach Availability Technology integrates policy training and communication with other compliance program components like compliance and ethics training for holistic recordkeeping and data analysis. Technology permits permissionsbased and enterprise-wide visibility on demand. Technology delivers the correct version and language seamlessly. Technology allows policies to be accessed, consulted, updated and managed without the confusion of email clutter. Contact Carole S. Switzer [email protected] for comments, reprints or licensing requests ©2012 OCEG visit www.oceg.org for other installments in the Policy Management Illustrated Series 1 0 0 0 1 0 0 1 1 0 1 1 0 0 1 1 0 1 1 0 0 0 1 0 0 0 1 0 1 1 1 0 1 1 0 0 0 0 1 0 0 1 1 0 0 0 1 1 0 1 1 0 1 0 0 0 1 1 1 0 1 1 0 0 1 0 0 1 1 0 1 1 0 1 1 To defend itself and validate an effective compliance/policy program the organization should be able to have a complete historical record of policy communication and training. TESTING To ensure understanding, the organization should test comprehension on critical/high-risk policies to ensure that they have been properly communicated and understood. ACCESSING PAST RECORDS 0 0 0 1 1 1 0 1 0 1 0 0 1 0 1 1 1 0 1 0 1 0 0 Defending the organization in legal and regulatory actions requires that a 360 degree view of the history of the policy, interactions with the policy, and policy communications be accessible with defensible audit trails. REPEATABLE CYCLE Communication is never complete. Repetition using different methods and tones can increase understanding and compliance.
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