Compliance Perspectives

By Adam Turteltaub Are your helpline calls being responded to properly? Are the investigations proceeding expeditiously and properly? To find out, it’s good to do an audit periodically. Before you can begin, though, you need to determine if there is enough available data for an audit, cautions Juliette Gust, President of Ethics Suite, and author of the chapter “Auditing the Confidential Reporting Hotline and Case Management Program Effectives” in the new edition of The Complete Compliance and Ethics Manual. Many compliance programs still do not have formal processes in place, and for them, it’s best to start with a gap analysis. If you do have data, look at how you are tracking both the allegations and the work being doing as a result. How quickly are allegations being reviewed? Is someone letting the reporter know that their allegation has been received and is being acted on? How are you safeguarding the data, including being sensitive to the potential need for attorney-client privilege? Spend time, too,