Executive coach and former Chief Compliance Officer Amii Barnard-Bahn responds to your anonymous questions on some of the grayer areas compliance officers face, such as culture, hiring, training, and ethics. Click here to submit your own for inclusion in our next edition.
Q: Our company doesn’t have a policy on the ethical use of AI, yet I know it’s being experimented with on the product level. Is this something I should elevate immediately? And what’s the right context in which to have that conversation? I’m at the director level, so not C-suite and not in every important meeting, but I feel strongly about this.
Amii: Your instinct to get involved is spot on; it is important for compliance to have a voice in product development, and this is especially true with emerging technologies such as artificial intelligence. Whether you should elevate immediately depends on the severity of the risk … and you may not have enough information to evaluate that yet.
Assuming you don’t yet know the gravity of the risk, my first step would be to learn as much information as you can. Build a relationship with key stakeholders on the product development team. Stay open and curious. Gain their trust and support by authentically positioning yourself as a business advisor who will help them navigate potential risk issues and what’s needed to move forward.
At one company where I led the compliance function, my team gently nosed our way onto a product team after catching wind that it involved both PHI and PII. We convinced the team that information lifecycle mapping during the product phase was less costly when done early (pre-launch) and would be an attractive selling point to clients. We were right—and clients loved it, so much so that the product team volunteered to be the beta test for our company’s first privacy ISO certification. They became our biggest advocate in the company, convincing other business teams to include us earlier.
Explain that including you early in the process helps to avoid costly changes and delays that could occur if risk is found later in the development versus building protections in now, which does not add much overhead or lost time. It often helps to have very specific examples (e.g. things that have occurred in the news or even at your company) that illustrate why having compliance engaged earlier in the product-build process is a wise approach before going to market.
Q: What’s the best way to know when it’s time for a job change? I like my job, but there’s no clear path to where I really want to be at this stage of my career. Is that a good enough reason to leave? I work for a small company where opportunities are hard to come by, and there’s a hard ceiling.
Amii: Yes, lack of advancement opportunities is a good enough reason to leave. You are wise to begin noticing this now. Many people wait too long and can get stuck and feel backed into a corner, taking the first thing they can find once they’ve reached the end of their rope.
At small companies, you almost have to eventually leave to gain more experience, continue to be challenged, and grow professionally and personally.
If it would be helpful, have an honest and open career discussion with your boss regarding next steps. If you confirm that advancement is not possible at your company (e.g. if you have “topped out,” or your boss isn’t going anywhere soon, or your company is experiencing a downturn in its business), you may need to decide whether to hold in place or make an external leap.
Sometimes it makes sense to leave. If you’ve been in your role 3-5 years and your growth or access to challenging work is declining, it may be time to consider a change. Lateral moves are often required to move up in any career. Sometimes even taking a temporary step backwards to pick up an important skill may be required for long-term advancement.
Sometimes it makes sense to stay. You may be getting the experience you need at this time in your career. Or your current role may be allowing you to focus on other important priorities in your life. Or perhaps you love your organization and are biding your time to see if a promotion is in the cards (e.g., if an acquisition or market expansion is on the horizon that could create opportunity for your role). Consciously “waiting it out” is a respectable strategy—just set a timeline that feels comfortable to you and keep learning during this time.
Q: Best way to get face time with the decision makers? And no, it unfortunately does not happen organically.
Amii: If it’s not happening organically, there is really only one path to gain time with decision makers: Get their attention by demonstrating you have something they need; deliver value by helping them achieve their goals; and get to know their business and build the relationship.
Pick one or two key decision makers whom you find most approachable or those you feel have the most to gain by a strong relationship with compliance and ethics. Consider increasing your frequency of contact (possibly one or two levels down) so you can receive information that enables you to be helpful to them. For example, with some stakeholders it may be valuable to set up a quarterly or monthly check-in.
Gather information about their key deliverables for the year (or their long-term strategic plan) and think strategically about contributions you and your team can make to help achieve their objectives. Your stakeholders are under business pressure just as you are. If you know what is important to them and can assist, your relationship will build and you’re likely to gain regular access.