By Adam Turteltaub
adam.turteltaub@corporatecompliance.org
Last week we witnessed a string of simple human errors that led to problems of epic proportions.
The Oscars snafu is, of course, the Oscar winner in this category. For anyone who happened to miss this one, the accountant at PWC responsible for handing out the envelopes for the presenters to read, accidentally gave out the wrong envelope for best picture. “La La Land” was announced as the winner, only to have it revealed that “Moonlight” had actually won. It led to chaos on the stage, endless coverage in the press, many late night comic jokes, and even a great prank by a UK theater. The lights went down, and instead of “Moonlight” coming on, twenty seconds of “La La Land” appeared on the screen. The audience reportedly laughed its collective head off.
This humor aside, much chagrin followed the initial mistake, along with a very big black eye for PWC.
They can take solace, though, in not being alone. On March 2nd, Amazon.com revealed that the massive outage in their cloud server business was caused by human error. While most people think of Amazon as a retailer, the company has a remarkably large business, known as S3, serving tens of thousands of sites around the web, including companies such as Netflix, Spotify and Pinterest. Not all the sites were down, but it was a long four plus hours when the S3 service was offline.
Finally, earlier in the week, Boeing revealed a data “breach” caused when an employee emailed a spreadsheet to his wife to get her help in formatting it. What he didn’t know was that there were hidden columns in the document containing personal data on 36,000 employees.
All of these incidents are a good reminder that people are only human. No matter how much training is involved, no matter how strong the controls, someone is going to bungle things badly.
It’s also a good reminder that not all compliance breaches are mal-intended. Sometimes, somehow things just get messed up.
But the biggest lesson here is that we should never feel complacent. The capacity to create controls is almost always surpassed by the human capacity to do something totally unexpected that somehow gets around them. Bottom line: given the opportunity something will likely go wrogn. Oops, I mean wrong.
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One aspect that human errors provide compliance professionals…JOB SECURITY!
Frank, I think you are right.
And thanks, Adam, for the “reality check”!
Thanks for chuckle, Frank. Sadly, it’s true.
…unless those mistakes are ours as compliance personnel. Then our job may not be all that secure.
Good reminder, Adam. We are all prone to error. That’s why a mainstay in our profession is a focus on process management. Regarding the Oscars, I can’t help but to think that if the PwC accountant had been carefully following the laid-out process that is a mainstay of his profession, instead of being sidetracked by backstage events, he’d not have lost his credibility. Too often, we forget the value of adhering to a well-established procedure for all kinds of reasons. And then we learn.
What I like about Adam’s posting is that it begs the question:
“How many times have we as compliance professionals been distracted (whatever that may mean on an individual basis) which caused us to make errors?”
Now I know here are some compliance professionals that it is simply not in their DNA to admit they ever made a mistake…but for the rest of us…a good reminder for us to look at processes from different angles so as to mitigate that which we can.
At the same time, easy to also understand that there is likely the possibility that we may overlook a particular stone that goes unturned…until we stub our toe on it. Ouch!
Let’s not forget either that as “effective” as a compliance program, or an auditing process, may be, effectiveness is not perfection. And, fortunately, most errors are not on live TV.
If on one hand we can never feel “safe”, or complacent as Adam perfectly stated, we can not run around with our hair on fire for every single problem that happens, as Roy Snell usually remembers us.
Balance is the keyword, risk assessment is the method, knowledge (of compliance programs and of your company’s operations) is the core of it all.
Thanks Adam
I hope no one is inferring that “perfection” in any shape or form is even in the conversation when it comes to discussing an effective compliance program.
As I see it, the operational or practical spectrum between “reasonable and perfection” is infinitely wide. No doubt we want to exist between these two, but let’s also realize the immensity of the idea of “perfection” though sometimes that term is tossed around so casually.
As I’m often reminded, perfection is the enemy of good. And we perfectionists struggle with that. If we as compliance professionals fail to admit our own human error, I believe we can’t be the very best compliance professionals. Humility and empathy are desirable traits, and no process is foolproof. (Even the word “foolproof” makes me chuckle a little — or sometimes gasp in horror.) Let’s be as real as we can. The people who simply “screw up” and the people who willfully commit malfeasance are generally not the same people. But they both need attention. And genuinely good reasons to behave differently.
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