Five Obstacles to IG Policy Approval
In the best circumstances, a well-crafted draft IG policy will sail through an approval process like a ship in warm water with strong breezes.
Too often, though, the proposed policy hits an iceberg, which stops it in its tracks. At best, there’s little damage and the approval process can continue; at worst, the ship sinks and you head back to the drawing board.
Here are five situations that commonly pose obstacles to quick policy approval, and how to get past them:
1. Too Much Baggage
The policy is bloated with non-policy statements.
Non-essential material that comes along for the ride unnecessarily puts a strain on the engines of the decision-makers, who have limited time. If you want your decision-makers to have context, explanatory, or illustrative material to help them understand the issues before approving the policy, put those into a separate coversheet.
We can take a lesson from the way government legislation is handled. Legislative bills submitted for approval are not padded with paragraphs of background or instructive material. Including extraneous material would only delay passage. The proposed text requiring approval is isolated in a separate document, and that document is limited strictly to statements that need approval in order to go into effect.
2. Too Broad
The policy is overly inclusive, covering multiple topics.
Say you have 400 rules around the management of information. Whether they are divided among four policies of 100 statements or 100 policies of four statements, the regulatory effect is the same. The number of policy documents has no impact on their applicability or enforceability nor on the implementation of standards and procedures under those policies.
It does, however, impact the speed at which the documents can be approved. The more areas covered in the proposed policy, the more areas where an approver can trip up.
Moreover, putting all those rules into one document sends a message that they are all of equal significance, but normally that’s not the case. What would you think if you were taking a cruise, but departure was being held up for a week because the dinner menu wasn’t approved yet? Separating major decisions from minor ones is a recognition of the difference.
3. Too Many “Weeds”
The focus gets lost in the details.
There’s nothing wrong with policies, standards, or procedures that contain technical language when that language is required. But there’s a clear distinction between the roles of (1) the people working in service delivery or operations and (2) those responsible for oversight of the organization. If your Senior Executive Management Committee—or equivalent—is spending time deciding whether a filename should be able to contain hyphen, that reflects a problem with the division of responsibilities and governance in the organization. Senior management needs to stick to strategy and oversight, and let IG subject matter experts manage the “weeds.”
As a policy drafter, you can encourage this separation by splitting oversight from detail and then incorporating into the oversight-level documents the principles that should govern the details documents.
4. Too Early
The organization is not ready for a policy.
In a well-managed organization, you can start at the policies and procedures and trace a line up connecting them to the organization’s IG programs and strategies, then continue the line up to its values, and ultimately up to the mission and vision of the organization. That system of origin and inheritance is a sign that the entire organization is working on the same plane.
When pieces are missing, the line is broken and it’s harder to complete the pieces underneath. Good policies are the output of strategic thinking, not the catalyst for it. The strategy drives the policy, not the other way around. Trying to draft a policy for an IG program in the absence of a defined strategy is an uphill battle.
Sometimes the best approach is to defer the drafting and submission of a policy pending the clarification of various elements of strategy, of corporate values, or even of the overall vision.
5. Not Prepared
The decision-makers are being asked to do too much at once.
Change management principles apply when trying to influence behavior above you, not just behavior below or alongside you. You may need to prime the pump by sending targeted communications to the decision-makers ahead of time.
A study undertaken in a supermarket illustrates the point well: In part 1, someone holding a cheese tray asked passers-by if they’d like to try a sample. The majority of people declined. In part 2, the same person holding the same tray of cheese asked passers-by if they considered themselves to be adventurous. The majority of people answered yes to that question. Only then were they offered the cheese, and there were far more takers than in part 1. No one likes having to make a decision without warning, or to feel rushed. If you want the approval process to be smooth, it helps to lay the foundation early: shop around goals, concepts, values, and principles supporting the statements you plan to put before them in the policy. Once those waves have made their splash and then died down, you can expect smoother sailing.
