Big data may be all the rage in the technology space, but data doesn’t have to be so big to be a powerful tool for compliance.
At Compliance Week 2018, compliance officers shared tips on how they have developed innovative uses for data to better strategize an approach to compliance and even make a case for added resources.
For starters, compliance officers do not need to be data experts to leverage it to their advantage, said Christopher Annand, director of global ethics and compliance for agriculture and food company Cargill. “I’m not a computer programmer,” he said. “I didn’t take statistics in college.”
It doesn’t take data science expertise to leverage data that’s likely easily accessible, correlate it, and use it to tell a broader story to stakeholders and business partners, said Annand. In fact, with more than 150,000 employees spread across 70 countries, he relies on data to provide insights that otherwise might be missed.
As an example, Annand said he can glean plenty from training data—how many people have completed it, how much time they spent in training, how they received their training—but that doesn’t necessarily speak to the effectiveness of the training to sway how people will behave. To try to measure that, the company deployed a platform that asks people to react to specific scenarios to get a sense for what kinds of decisions they might make in certain situations.
Data from that platform helps Cargill determine not just whether employees completed a particular training module—but also whether they got it. “We’re more interested in knowing if you face this situation, what action do you take?” said Annand. “What’s driving that decision?” That helps the company get a better understanding of where its risks might lie, he said.
Susan Castaneda, compliance officer at The Hartford, advocates using data about culture and incorporating it into the overall risk assessment for the business. The company employs about 15,000 people across the United States, many of whom work from home offices, she said. That presents some compliance challenges the company has had to navigate, she said.
The Hartford’s use of data includes not only inherent risks, but also residual risks, which is then leveraged by the compliance office to help make a case for added resources. “We use that data to really frame the conversation with business leaders,” said Castaneda. “So that when they’re looking at that bill associated with hiring all those compliance professionals, it helps them understand.”
The company also seeks to integrate data that speaks to cultural issues, like data emerging from training programs or data that speaks to overall work environment or ethical mindset of employees, and factor that into overall business risk assessments. Business leaders can even be held accountable to that data year over year, said Castaneda.
Ilona Niemi, vice president and chief compliance officer at Zurich Insurance Co., said data is critical to compliance resource planning and allocation. As part of the company’s annual planning process, data is used to demonstrate where the company may need to allocate more resources to keep it safe, she said. “It takes a little pressure away from the compliance organization,” she said.