By Roy Snell
roy.snell@corporatecompliance.org
Policies are often conceived of for good reason, but those who write the policy tend to make the policy more complicated and potentially onerous than is needed to achieve the spirit of the policy. People occasionally suggest a policy that inconveniences many people be written to address an issue that rarely ever happens. Occasionally, the people who ask for the policy are the people inconvenienced by the policy. The point is, the law of diminishing returns can apply to policies too.
Employees often say things can’t get done quickly because of all the bureaucracy. A strong leader can reduce this problem, but not without criticism associated with refusing to write a complicated policy every time someone demands one. Bureaucracy is a choice; however, for some reason, it must be a tough choice because we all end up with so much bureaucracy.
Having no policies is possible, however, it is a ridiculous idea and most everyone seems to agree with that perspective. Having some policies is possible and necessary, and most everyone seems to agree with that perspective too. What we seem to have trouble agreeing on is when to stop writing or unnecessarily complicating a particular policy. Some people think more is better. Some people think the more complicated their creation is, the better their creation is. People often write policies to cover every eventuality regardless of the odds that a particular eventually will occur. As a result, some policies become more problematic than the problems they are intended to prevent or fix. I have watched people question where all the bureaucracy comes from while they are creating more bureaucracy.
Somehow we don’t see the negative downstream impact of an onerously written policy as we write it. We all get a little indignant occasionally about an issue and passionately pursue a good policy relating to the important issue. I am all for developing policies. I am just suggesting that we should be more careful about writing policies that have negative unintended side effects on people and companies. We should revisit the wording of policies every once in a while to see if the policy is still needed or if the policy has had unnecessary negative impact that can be easily fixed. Although I doubt it will ever happen, I would consider creating a position of Compliance Policy Simplification Coordinator. They would wander the organization looking for good intentions gone bad and work with the department to unwind the unnecessary bureaucratic unintended consequences of a policy.
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The role of our Policy Analyst is to create or rewrite policies so they are formatted consistently, use the same vernacular, and cross-referenced with associated policies before being posted to our intranet. A couple of years ago we began a process of reviewing policies and pulling related ones into a single policy; this reduced all the blah blah blah of page header formatting and made policies much easier to navigate. For example, our holiday, sick, vacation and other policies were pulled together into a paid leave policy; overall we reduced the number of admin policies by two-thirds. We created a meta-policy, or policy-on-policies, that describes our protocol for policies. Every policy goes through the Policy Analyst before it can be official and get versioned. This has taken the load off of policy owners, who no longer have to attempt to write a treatise when a clearly-written policy and a few procedures will do the same job.
Genius. Others could learn from this. We would love to have an article describing the process you have for policies. If you are interested email me at roy.snell@corporatecompliance.org and I will connect you with Liz our Editor for the SCCE monthly membership publication.
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