Cybersecurity threats and massive data breaches continue to plague the healthcare industry both in volume and sophistication. Securing intellectual property and safeguarding sensitive customer information will undoubtedly remain a high-priority challenge across organizations of all shapes and sizes well into the future. However, the days of placing responsibility solely on the internal IT organization is no longer sufficient. Today’s organizations must understand broadly the need to educate and equip teams across the entire enterprise with the tools and training necessary to cultivate an effective culture of compliance.
SECURITY ≠ COMPLIANCE
It’s important to understand that more or better security does not equate with compliance. A single group tasked with security does not build a foundation for a corporate-wide culture. A compliance program is a program of due diligence that involves human processes and stepwise procedures which:
Reduces legal and regulatory risk
Reduces the number and effectiveness or reach of common threat vectors
Documents all normal activities in a consistent manner which highlights deviation or abnormality and provides forensic evidence of such deviation from the standard
An effective compliance program works with functions and procedures that drive revenue and make people more efficient at their jobs. It also gives workers a framework of repeatable procedures and logical processes. When a compliance program is executed correctly, it will have little to do with IT. Compliance is fundamentally a business operations issue.
CREATING A CULTURE OF COMPLIANCE
The first and most important step in creating a culture of compliance across an organization is establishing ownership from the business operations executives. Operations executives are ultimately responsible for culture at the company, and a culture of compliance is not an exception. Once communicated, all employees and knowledge workers are then accountable for understanding logical processes, following them, iterating the procedures of the program and understanding the framework. The IT staff, as with the technological tools they employ, are responsible for supporting those procedures as they are executed through the various IT systems. The cultural component absolutely must start with business operations.
A compliance program will ultimately fail if it does not have universal buy-in across the entire organization. Yes, communicating policies and procedures is important. Yes, training is important. However, compliance programs will only succeed if the tools provided make the employee’s job easier, not harder. Workers should be thrilled to use the tools provided to them because they make their workflows more efficient.
A good place to start when developing a compliance program is with existing government or industry-specific guidelines. These guidelines will cover the broadest base within an industry. Depending on the industry, compliance may be required by law, but it absolutely must also be employed as a fundamental tool for building competitive advantage.
Next, leverage internal guidelines and industry best practices. Beyond the marketing value of exceeding procedures mandated by some federal or government entity, an effective compliance program will have the dual utility of providing increased security through lower risk and reduced threat vectors, as well as greater performance due to reduced errors and rare abnormalities.
One of the key drivers of success for any compliance program is participation. People will get on board with compliance or a new program when logical processes make sense and help them do their job more efficiently. If shadow IT has taught anything, it’s taught what the user community is willing to accept and the technology they are willing to use. Technological tools, such as a virtual data room—that have a very easy learning curve—can have a significant impact on driving adoption.
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