Discussions on compliance analytics typically revolve around technology—what is needed and how should it be implemented? However, for organizations to be successful, they should consider another piece of the puzzle: the right talent. The following are some key considerations when assessing talent needs for a compliance analytics function:
Tone at the Top
Many organizations try to build a robust compliance analytics program with the goal of increasing coverage, transparency and efficiency. The key differentiator between successful programs and those facing repeated headwinds and do-overs is the tone at the top. CCOs, CROs, CFOs, audit committees and business line leaders must all be consistently encouraging compliance practitioners to use analytics, empowering them with the tools and resources to do so, and holding themselves and their peers accountable for progress.
It is easy to recommend that an organization evangelizes the use of analytics, but not as easy to achieve lift-off and remain in the air. For an executive team to maintain momentum, and ultimately build a culture of analytics within not only compliance but across business lines, they need a defensible value proposition. The critical step here is to objectively quantify the value that analytics provides, which is only realistic to the extent that an organization is tracking some baseline metrics that can be used to evaluate the efficacy of the program with and without the use of analytics. For example, a good thing to know might be the types of controls are being executed and tested, and how much time is spent doing so. Without this information, it is difficult to identify candidates for automation as well as the impact of analytics when applied to a particular control test or execution.
To address specific talent needs for a compliance analytics function, organizations need a candid assessment of the current state and realistic short and long-term goals. Conducting a maturity assessment is an important, recurring step in developing a compliance analytics program. There are many analytics maturity scales for risk and compliance or other business functions, almost all of which are comprised of four broad buckets:
- Basic: the ability to do ad-hoc reporting on an occasional, as-needed basis.
- Foundational: the ability to have consistent standardized reports on a recurring basis that articulate what has happened in the past.
- Optimized: the ability to connect the dots across reports from different business units, often encompassed by visual aids and dashboards, to influence current business decisions without employing armies of professionals.
- Leading: the ability to continuously monitor, predict, and anticipate emerging risks proactively.
Most organizations do a good job of identifying where they are on a compliance analytics maturity scale. However, a common pitfall is that organizations try to accelerate their path to having an optimized or leading compliance analytics function in a siloed fashion by making a few key hires—particularly of people that have the skillsets representative of a leading function, but without doing their homework and evaluating their current talent pool and organizational structure.
Once some initial analytics projects are identified, it is important to assess whether the talent to drive these projects already exists in the organization. This helps determine whether it makes sense to leverage a centralized pool of talent that can build solutions for the compliance department, whether the compliance department should hire technologists and data analysts within its function, or whether to start by onboarding contractors to establish some quick wins that can eventually be assumed internally once the analytics program is more scalable and mature.
Regardless of where an organization lies in its compliance analytics journey, all will benefit from having data savvy professionals, even if these professionals traditionally reviewed policies and procedures, or design business controls. This does not mean sending everyone to statistics and data science boot camp, but it does mean setting up an effective screening process where technical data analysis skills are evaluated during the hiring process, not just demonstrated knowledge of controls or business functions. It also means setting up an effective training program for experienced professionals to make the most out of their existing tools, using real case-studies from past business activities or compliance projects. The specific topics and skills that are the focal point of an analytics training program should be highly influenced by examining the organizational structure and identifying gaps in skills required to achieve short-term goals.
In summary, the basic steps to build compliance analytics talent are to:
- Employ good information management practices that equip executive leadership to sustain a promotional tone on using data analytics
- Conduct a maturity assessment that includes an evaluation of organizational structure and existing analytics talent
- Refine hiring strategies and develop a training program that addresses gaps between analytics skills and analytics needs
When it comes to risk and compliance, the data can be complex. For organizations to thrive, they must consider having the right talent and an effective risk-data infrastructure before trying to glean any insights from the information at their fingertips—otherwise, they will end up where they started time and again.