Information Nation: Seven Keys to Information Management Compliance, Second Edition
by Randolph Kahn, Barclay Blair
Key #6: Effective and Consistent Program Enforcement
Information Management program policies and procedures must be consistently enforced through appropriate disciplinary mechanisms and the proper configuration and management of Information Management–related systems.
Key Overview
The existence of a compliance program is not sufficient, in and of itself, to justify not charging a corporation for criminal conduct undertaken by its officers, directors, employees, or agents. Indeed, the commission of such crimes in the face of a compliance program may suggest that the corporate management is not adequately enforcing its program.
"Federal Prosecution of Corporations," U.S. Department of Justice[163]
Key #5 addressed the need for organizations to employ Information Management auditing and monitoring programs to measure compliance and detect program violations. This section explores what happens next: Once violations are detected, how should they be dealt with?
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