You should work to create an action plan to use your data. But never forget you need to get your digital information right. That means several sources of data to help you choose the best course of action. Earlier this year, Deadspin reported on a joint investigation between BuzzFeed UK and the BBC, in an article entitled “The Tennis Racket”, which looked at what they believed was suspicious betting in professional tennis matches. They used a transactional analysis to come up with the players involved and matches they allegedly fixed at the behest of gamblers. This use of data analysis pointed to this key lesson, data analysis is only the starting point in any investigation. You need to review other data to make an action plan. Other sources of information might include interviewing witnesses, reviewing documents, looking at injury factors that might have influenced the outcome of tennis matches. It is not simply enough to identify suspicious activities, you need to determine the facts behind the numbers and then analyze both the numbers and the facts. If warranted, remedial action would then be appropriate. Any best practices program should prevent, detect, and remediate.
Another important point is the integration of compliance data into your overall business strategy. One area that compliance is often criticized is that it does not support an overall business goal. By determining a way to use compliance analysis from your data in a manner that supports the business unit going forward, compliance can become an input into business strategy. An example might be in your sales models. Does your business use employees, commissioned sales representatives or entities such as distributors to sell? All of these present not only different types of compliance risks but different types of compliance solutions. By building relationships with all levels throughout the company, you will have the opportunity to move into the trusted business partner realm.
This also means looking outside the compliance discipline for inspiration and innovation. Design thinking can be a key way for you avoid getting stuck in a specific paradigm inside your own organization. Think about what your internal or external clients will need to be able to do business in compliance, with the top risk management in place to allow them to move forward. Finally, practice transparency. Remember you are not the legal department, keeping information close to your vest. The compliance mandate is different. If a problem arises, the first job of the CCO is to fix the problem.
Key Takeaways