See attached for how my organization defines this overall process. Basically, all "policy" documents require executive management approval; the owning department manages all other documents. Compliance, however, owns the publication of all related document types (Policy, Standard, Process/Procedure, Guidelines), so all documents, we feel, are sufficiently reviewed before publication, even though not all require corporate executive approval. We're structured under a holding company with multiple subsidiaries, but we're actually a fairly small company, with less than 500 employees (combined).
It may be worth walking through one of the documents with HR and helping them identify a statement of policy vs. a statement of standard/procedure/guideline. When I'm reviewing/revising policies, I help myself identify some of these statements by saying, "Management has decided that..." and then read the sentence. It takes a little practice, but it starts to become clear after a while.
For (a very short) example, (policy) All full-time and part-time employees are entitled to Paid Time Off (PTO). (Standard) Employees start earning PTO their first day of work, but accrued PTO may not be used until the employee passes probation. (Procedure) At the end of a fiscal year, an employee's unused accrued PTO balance, up to the rollover cap amount, will automatically carry over to the next fiscal year. (Procedure) Employees who wish to utilize their available PTO balance must submit requests to their immediate supervisor. (Guideline) Employees may request a payout of unused PTO at any time throughout a fiscal year if the following guidelines are met (insert desired guidelines).
While we haven't updated our process in a few years, we subject our policies to reviews (as outlined in this document), and those reviews are recorded in Compliance. I would be very much interested to see how others govern their policy adoption and change processes as well!
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Clancy Byerley
Compliance Assistant
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Original Message:
Sent: 07-27-2021 06:52 PM
From: Kathryn Dailey
Subject: Policy Governance Framework
Hello everyone!
I'd like to open up a discussion on how others are governing their policies. For example, how you define policy vs. standard vs. procedure vs. guideline and how you govern each of those.
We are implementing a Policy Governance Framework and we have hit a hiccup. Our thought is that our Risk team will govern all policies, but not all standards, guidelines and procedures as there are plenty of them that aren't relative to the entire workforce. However, HR would like to call almost all of their documents "policies", even though we find some of them to be more of a standard. In my previous experience, the policies that we governed were called "Compliance Policies" and the rest were guidelines, procedures, notices, etc. that were not governed by the team. We don't want to use the word "policy" too loosely because we don't want to lower the significance of the actual material policies that we have. Does anyone have any thoughts or insights on this?
Thank you!
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Kathryn Dailey
Compliance Specialist
Richmond, VA
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