For the purpose of this article, the question “Why do you manage Compliance?” is specific to the ‘Compliance areas’ that the industry is currently zooming in on; Gas, Electrical, Asbestos, Lifts, Water, FRA and all associated disciplines that form part of each of those categories.
When I asked the team at TCW the question above, the answers we discussed were so insightful that I realised the question should be regularly asked in Housing team meetings. Understanding perceptions of compliance, assurance and risk is a great first step towards understanding that in Housing we do NOT manage compliance. We manage the process and throughout that, we put a tick in a box which confirms compliance at different stages or milestones.
I’ll give you a couple of examples:
1) When procuring a contract, the team responsible will share a very confusing Gantt chart. Each line with a due date. Meeting these dates results in being compliant with the process.
2) We are required to have a Fire Risk Assessment on Block 1 TCW Street on or before the 1st Feb 2021. If the work is complete on the 31st Jan we are compliant with the first part of the process.
However, what about the actions in the document and how many streams will this create meaning more compliance ticks are required over an extended timescale.
So, how do you manage something that can move the bar any time it wants. I guess the answer is simple if you are willing to accept that at any one time you will always be non-compliant with regards something. This is why I struggle to accept when someone bursts on social media about being 100% compliant on their Gas Safety annual servicing. I’m not questioning that they are 100% compliant with regards to all properties being within a defined process, but that is not the message they are projecting.
One of the main things that isn’t being managed, or isn’t helpful at the moment is the ‘white noise’ and the sales pitches from brands around the globe. The issue here is not that these brands don’t understand compliance, it’s more the interpretation of what Compliance means to them and/or the products/services they’re trying to sell. Trying to find an angle to instil thought in a person you want to sell to is far easier if the market is worried about something.
What’s important in all of this is how we perceive risk and, how we perceive the good management of said risk? Interestingly, when I first started working for Leeds City Council I was responsible for the Quality Assurance aspect of management Electrical Compliance. My title was Quality Assurance Officer for a short time. It was right at the beginning of my time in Housing when I realised your Compliance fuels my Assurance, it doesn’t complete it but it’s the flour to my eggs, milk and butter.
I started to realise that the information I was receiving provided other people with more insight and fuel to fulfil what they are required to achieve. This could be communications in emails, compliance reports or certificates, meeting notes and phone calls. Not only that, a wrong word had the capability of impacting someone I’d never met.
Example: I remember I attended a complaint in Leeds where the resident was angry that they had not been placed on a list to have significant work carried out. During the conversation in the tenant’s lounge, we started to discuss air purification that residents on the street had installed themselves due to the properties being near a busy road. The resident was angry that they had to do this and that the filters were now obsolete for the devices they had.
As someone who always wants to help, I managed to source five filters from a European provider over the internet.
I hand-delivered these thinking I was doing this resident a favour. Going the extra mile as they say.
In the five minutes it took me to arrive back at my office I had several complaints from residents on that street asking for filters. This then resulted in a scheme to replace them all.
A good deed rewarded.
Stories like this that help me exemplify what TCW is about. We try our hardest not to dine off the back of pain and failure in our sector but understand that sometimes the solution is fuelled with what happens around our sector. Having an understanding of Compliance and Assurance means we have developed a platform that provides a single location (folder) for Certificates and Reports across all compliance disciplines. The software removes the human element by checking regulatory and client-specific obligations. Not only that, the software then provides a managed process for Corporate Risk Actions that arise from the documents you receive. Having visibility and insight into both the actions and then the process to rectify is essential. It’s also very important to understand that one shoe does not fit all, your requirements need to be managed to fit your organisation’s existing management processes.
So, what is Compliance?
Below is the answer our Chief Technology Officer provided when I asked our team the question. I think you’ll agree it is bang on.
“If you operate purely reactively to issues that arise you can only fix those issues. In applying a predefined policy across all elements you not only can catch and fix those issues before they are critical, but you also have visibility of any number of other aspects that you want to apply a policy against (to facilitate planning etc). Precisely why anything other than understanding 100% of your exposure is effectively useless”.
Ryan Dempsey is Chief Executive Officer of TCW.
TCW, is an innovative technology company, who have developed a unique solution to a very real problem within asset management for a number of sectors. Primarily within Social Housing TCW has enabled duty holders to gain assurance that their compliance documents have been analysed, stored and checked to regulatory obligations