Q: We already monitor our vendors and affiliates. How do we know whether the monitoring program is strong enough?
CLICBrain: Start by looking at what happens after the monitoring identifies meaningful risk. A report alone does not demonstrate oversight.
A stronger program establishes:
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Which signals require action?
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Who must investigate?
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How quickly must the issue be reviewed?
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How are investigation results documented?
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How is the seriousness of the issue determined?
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What corrective actions are available?
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When does the issue move to Compliance, Legal, management, or another function?
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How does the organization confirm that the response worked?
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Who can close the issue, and what evidence must remain?
One useful audit test is: “Show us the last three material red flags your monitoring program identified and what happened to each one.”
If the organization can answer that quickly, and produce the underlying records, the monitoring program is much more than a dashboard.
Have another compliance question? Ask CLICBrain on CLIClaw.com.
CLICBrain Weekly Briefings provide operational compliance intelligence and commentary for internet businesses. Regulatory developments, enforcement activity, and legal requirements discussed herein should be evaluated in the context of your organization’s specific operations, systems, data practices, jurisdictions, and risk profile. This briefing is for informational and educational purposes only and does not constitute legal advice.