How to Maintain Regulations and Associated Relationships in Axon

Challenge

Regulations can be amended by the regulatory bodies that created them and change over time. After loading a regulation into Axon, it’s important to keep the regulation up-to-date and perform an impact analysis via a change request/workflow process on the policies that are connected with each section of the regulations that have changed in order to determine if the policies also need updating.

If policies do require updating because of the regulation change, further impact analysis via a change request/workflow process can be done on the systems, processes, and glossary items related to each of the policies that are also changing to determine if the policies still make sense being associated to those items.

Description

The purpose of Regulatory Amendment and Curation is to achieve the following:

1. Establish appropriate responsibility for the management of the Regulation facet in Axon.
2. Improve the integrity of the regulation and policies created from the regulation, resulting in greater accuracy, timeliness, and quality of information for decision-making.

This best practice applies to anyone, who is responsible for monitoring, managing, or maintaining Regulations and for creating company specific Policies based on those regulations. Its purpose is to help organizations establish a process to guide day-to-day usage and management of data in support of regulatory compliance and the above objectives. This applies primarily to the Regulation and Policy facets in Axon, but also may include other facets such as Systems, Processes, and Glossary items that may be associated with the Policies.

Regulation Curation Process

Step 1:  The amended law should be an update of the old law

1. To create new law/regulation start from scratch by downloading the latest Regulation in PDF format from the legislative/attorney general’s web site
2. Convert the PDF file to Excel
3. Map the new legislation/regulation PDF-based Excel to the last-used Axon Regulation bulk upload template, replacing the text for each section that has changed (make sure this version of the bulk upload template has the correct Reference ID used by Axon for each row).
4. Regarding the Attorney General regulations (still being drafted to interpret the law):

Q:  How often to look for law/regulation amendments?

A:   As needed. IAPP.org can be referenced for updates to existing regulations and the status of other new privacy regulations being enacted.

Q:  Who should know when new regulations/statutes happen?

A: Your company’s Legal/Compliance team will either need to keep abreast of this and notify the team’s doing the maintenance work on the Axon accelerator bulk upload spreadsheets or find a 3rd party service to monitor the regulations.

Step 2:  Upload template and initiate workflow process for approval

1. Upload the revised Regulation bulk upload template into Axon.
2. Initiate a Change Request for the Regulation to start the workflow review process.
3. For each section of the Regulation that has changed, find the Policies that are related to that Regulation Section.
4. Review each Policy to determine if it needs to be modified based on the changes made to the Regulation.
   
   NOTE:  Old law/regulation text is kept in the workflow history for reference.

Step 3: If Policies attached to old law/regulation need to be changed

Use a process similar to the one above for the Regulation facet:

1. Update the existing Policy text with new text provided by the Legal/Compliance department.
2. Create a change request to initiate the workflow process to review all the other facets related to the Policy and determine if the policy still makes sense for those facets.
   
   NOTE: The old policy text is kept in the workflow history for reference.
   
   
3. Once the review is completed for all facets related to the Policy, complete the workflow process for approval of the Policy changes.

Step 4: Additional Axon facet updates

Also keep the Terminology (Glossary) bulk upload spreadsheets updated if the definitions have changed in the Regulation.

Use the same process as above to update the old Glossary item definitions with new definitions and create a change request to initiate the workflow process to approve.

NOTE:  The old definitions are kept in the workflow history for reference.

Step 5: Axon Version Control

Keep the bulk upload and bulk update spreadsheets current with Axon versions as they change (every 6 months or so), making sure the column positions and drop-down choices are correct as Axon is upgraded from one version to the next.