Author: Jason Victor | i-Sight (now Case IQ) Director of Solutions & Support| Jason is one the original developers of the i-Sight (now Case IQ) solution and now leads the i-Sight (now Case IQ) IT & Support groups. He's been involved in over 150 i-Sight (now Case IQ) implementations including global implementations at Dell, Coca-Cola, AllState, Siemens, DSGi and many others.
Ensuring Compliance in a Decentralized Org. Structure
Companies operating globally face a growing number of employee relations and compliance related challenges. The most important challenge is their ability to adapt to local laws and cultures, while ensuring company-wide adherence to standards developed at head office. In order to operate on a global scale, many organizations have employed a decentralized structure. Although this is an effective strategy for enabling rapid decision making and customization of product & service offerings, it presents a significant challenge for compliance and HR professionals. More specifically, we've seen many clients empower their local HR teams to investigate employee complaints or reports of misconduct. This is a great approach, however I believe there needs to be centralized oversight for two major reasons:
1) Identifying Repeat Offenders: As employees move from one position to another, they will often move to an entirely different organization - within the organization. If an incident is only reported to the regional HR group, there's no way to communicate an employees history to the other regions. I was recently speaking to a client who told me of an employee who was moved around 5 times in as many years. In each new job, this employee's misconduct was reported to the regional HR group for investigation. Disciplinary action was taken in each case. The problem however; is that there was no coherent record of their misconduct. The disciplinary action should’ve been increasingly severe with each infraction; however, it wasn’t possible due to the lack of case history. If taken to court, this would be a difficult pattern of misconduct to defend and the organization’s inability to discover the pattern could be seen as negligent.
2) Identifying Potential Corrective Measures: Centralizing misconduct reports and investigations enables a global examination of trends that’s not otherwise possible. When each region acts as an island, it's impossible to identify global trends or take advantage of "serendipitous" discoveries. Most of our clients report at both a regional and global level. A key reason to centralize employee relations data is unintended pattern discovery. Using advanced analytics across the entire data set enables executives to identify global trends and take appropriate corrective measures. This may lead to re-writing of policy or providing enhanced training in certain areas.
Social Media and the Viral Impact
Thanks to the Internet and social media, a local workplace incident in one corner of the globe can very quickly become a public relations nightmare back home. Consumers expect that companies operating globally are doing so in a manner that's consistent with the values they represent at home. There's no excuse for failing to remain up-to-date on global laws and cultural norms. Although a company may have a viable defense in a court of law, the court of public opinion operates under a different set of rules, and the power of this court has become equally powerful. Although consumers may not issue fines or directly infringe on a company’s autonomy, they can seriously impact the value of the company.
HR departments must provide a timely response to every allegation. We often address these issues with our clients in a couple ways:
1) Record Every Allegation: Have local HR teams enter every complaint or report of misconduct - regardless of the perceived credibility. Even if every report isn’t investigated, the data will help form the global view we are looking for.
2) Categorize Risk Potential: Every allegation should be assessed for risk. This doesn't have to be overly scientific, but certainly a simple dollar value or category selection (high, medium, low) enables executives further up the chain of command to easily maintain visibility over high priority investigations.
3) Use Workflow Alerts: When a new case is entered in i-Sight (now Case IQ), notifications are sent to the appropriate levels and information is now available, and current, for those who need it. i-Sight (now Case IQ) uses automated workflow alerts that are triggered based on a combination of case related factors - including geographic region, allegation type and risk potential. Alerts can also be used when milestones, regulatory or otherwise, are not met. This helps bring attention back to the investigation.
All of the recommendations above need to be done while maintaining privacy and clearly documenting each stage of the resolution process. Documentation must be completed to meet court requirements, should the case end up in front of a judge.
Power of Collaboration
Homegrown systems that rely on spreadsheets, MS Word documents and emails just don't cut it. I've had the pleasure of witnessing first hand the power of collaboration. Although the Internet has raised the stakes by giving consumers a louder voice and a platform for rapidly sharing news about corporate malfeasance, it has also added to the arsenal of tools available to investigative teams. By centralizing information in an electronic case file that's available 24 / 7 to any authorized user within the organization, investigators are able to collaborate with their peers & managers to more readily obtain invaluable advice.
In this shared environment, security needs to be robust and granular enough to maintain privacy.
Conforming with Global Privacy Laws & Regulations
This topic deserves a post of its own, but here's an overview from the Rutgers Journal of Law & Urban Policy entitled "Binding Corporate Rules for Cross-Border Data Transfer". This was published in 2006, and I'll try and find an updated version when I write about this topic more specifically. In brief however, there must be safeguards in place to ensure the treatment of personal customer or employee information is consistent with the laws of each country or region.
Real Time Reporting Across the Entire Organization
Finally, when all is said and done, executives and managers require access to aggregated information in order to identify trends and take appropriate actions. To meet the needs of today's executives, spreadsheets, standalone databases and emails introduce an unacceptable lag in reporting. Information needs to be recorded in a consistent manner across the entire organization to enable effective decision making.